Countries that have committed to adopting and effectively enforcing forced labor import prohibitions will be subject to a 10% tariff, while countries that have failed to adopt a forced labor import prohibition will be subject to a 12.5% tariff.

Specifically:

• A 10% tariff will apply to the following countries: Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, and the United Kingdom.
• A 10% or 12.5% tariff, net of the Most-Favored-Nation (MFN) rate, will apply to certain products of the European Union, Taiwan, Japan, Korea, and Switzerland.
• A 12.5% tariff will apply to all other investigated economies, including Brazil, Costa Rica, China, the Dominican Republic, the Philippines, Thailand, and Vietnam.

An in-transit exception applies to goods that: (1) were loaded onto a vessel at the port of loading and were in transit on the final mode of transit prior to entry into the United States before 12:01 a.m. Eastern Time on July 24, 2026; and (2) are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. Eastern Time on July 28, 2026.

Exceptions include:

• All articles and parts of articles subject to Section 232 tariffs.
• Textile or apparel articles that are products of Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, or Nicaragua and are entered free of duty under DR-CAFTA.
• Any products of Canada or Mexico entered free of duty under the United States-Mexico-Canada Agreement.
• Informational materials.
• Goods for which entry is properly claimed under a provision of Chapter 98 of the HTS. However, for goods entered under subheadings 9802.00.40, 9802.00.50, and 9802.00.60, the additional duties apply to the value of repairs, alterations, or processing performed, as described in the applicable subheading. For goods entered under heading 9802.00.80, the additional duties apply to the value of the article assembled abroad, less the cost or value of such products of the United States.

For a full list of exemptions, or to discuss how these new tariffs will impact your business, please call us.

We will continue to monitor developments closely and provide updates as additional guidance or implementing measures become available.

For further information, please contact us.

The 25% duties will apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on July 22, 2026. An in-transit exception applies to goods that were loaded and in transit on the final mode of transit prior to entry into the United States before 12:01 a.m. Eastern Time on July 22, 2026, and are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. Eastern Time on July 29, 2026.

Various exceptions further apply to certain specified HTSUS provisions, as well as information materials and articles of aluminum, steel, or copper, and derivative aluminum or steel articles.

Additionally, the Section 301 duties do not apply to goods for which entry is properly claimed under a provision of Chapter 98. However, for goods entered under subheadings 9802.00.40, 9802.00.50, and 9802.00.60, the additional duty applies to the value of repairs, alterations, or processing performed, as described in the applicable subheading. For goods entered under subheading 9802.00.80, the additional duty applies to the value of the article assembled abroad, less the cost or value of U.S. products incorporated into the article, as described in that subheading.

For further information, please contact us.

In this regard, USTR determined that additional tariffs were warranted in response to the “acts, policies, and practices” of countries that have not effectively imposed and enforced a prohibition on the importation of goods produced with forced labor. USTR found the actions of those countries is unreasonable, burdens or restricts U.S. commerce, and are thus actionable under Section 301(b) of the Trade Act.

As a result, the USTR has proposed the following additional tariffs.

• A 10% tariff on products from the following that either currently impose (but have failed to effectively enforce), or have undertaken commitments to impose, a prohibition on the importation of forced labor goods: the EU, the UK, Argentina, Bangladesh, Canada, Cambodia, Ecuador, El Salvador, Guatemala, Indonesia, Malaysia, Mexico, Pakistan and Taiwan;
• A 12.5% tariff on products from the remaining countries under investigation, including Brazil, Chile, Costa Rica, Egypt, India, Thailand, and Vietnam. For a complete list of affected countries, please contact us.

It is expected, however, that these tariffs will not be apply to either USMCA-qualifying importations or on apparel eligible for entry under DR- CAFTA.

Comments this proposal are due July 6, 2026, and USTR will hold hearings about the proposed actions in these investigations on July 7, 2026. Those interested in testifying must advice USTR by June 22, 2026.

We strongly recommend that clients who will be impacted by these tariffs consider filing comments. We are available to assist with this process as needed.

For further information, please contact Gail Cumins at gcumins@spcblaw.com, Alli Baron at abaron@spcblaw.com or call us at 212-425-0055.