U.S. importers should prepare for substantial new tariff exposure following the Trump administration’s imposition of Section 301 forced labor tariffs on imports from 60 countries. The measures affect approximately 99.4 percent of U.S. imports and may result in additional duties, subject to certain exemptions and special tariff treatment.
The tariffs were announced on July 23, 2026, in a presidential memorandum in which the Trump administration stated it would impose tariffs through the Section 301 investigation examining whether foreign governments have failed to prohibit and effectively enforce restrictions on goods produced by forced labor. These new tariffs went into effect on shortly after on July 24 with a grace period for goods in transit until July 28.
Importers should promptly review affected products, evaluate available exemptions, and assess potential cost and supply-chain impacts.
Countries Subject to the Section 301 Forced Labor Tariffs and Applicable Duty Rates
Sixty countries under two distinct tariff structures are subject to the Section 301 forced labor investigation tariffs. A comprehensive list of the impacted countries is provided in the Presidential Memoranda.
Countries Subject to Additional Tariffs
- The countries subject to a 10 percent tariff: Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, and the United Kingdom.
- The countries subject to a 12.5 percent tariff: Algeria, Angola, Australia, the Bahamas, Bahrain, Brazil, Chile, China, Colombia, Costa Rica, Dominican Republic, Egypt, Guyana, Hong Kong, Iraq, Israel, Kazakhstan, Kuwait, Libya, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, the Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, Thailand, Türkiye, the United Arab Emirates, Uruguay, Venezuela, and Vietnam.
Countries Subject to Aggregate Tariffs
- The European Union and Taiwan are subject to aggregate of the Most Favored Nation (“MFN”) and the Section 301 tariffs duty rate must equal 10 percent.
- Japan, South Korea, and Switzerland are subject to aggregate of MFN and the Section 301 tariffs duty rate must equal 12.5 percent.
Products and Trade Programs Exempt From the Forced Labor Tariffs
Products exempted from the forced labor tariffs include:
- Goods subject to tariffs under Section 232
- USMCA compliant goods.
- DR-CAFTA compliant textile or apparel goods.
- Critical minerals and rare earths, such as vanadium oxides, aluminum hydroxide, and pig iron;
- Technological inputs, such as semiconductor manufacturing equipment (SME) and battery waste;
- Agricultural goods, such as in-quota sugar, fertilizer and pesticides, and certain planting seeds; and
- Consumer goods, such as worn clothing, antiques and collectibles.
Additional exemptions include:
- Country-specific product exemptions for countries that have concluded an agreement on reciprocal trade (“ART”) or similar agreement with the U.S. They include: Argentina, Bangladesh, Cambodia, Ecuador, El Salvador, the European Union, Guatemala, Indonesia, Jordan, Malaysia, Switzerland, Taiwan, and the United Kingdom.
- A tariff-rate quota (TRQ) system for certain textile and apparel products from Bangladesh, Cambodia, Indonesia, and Malaysia.
Key Compliance Considerations for U.S. Importers
The new Section 301 forced labor tariffs may substantially increase costs for importers from affected countries. Importers should:
- Proactively review their product countries of origin to confirm whether they fall within any of the applicable exemptions.
- Work with counsel to promptly coordinate with customs brokers and internal compliance personnel to ensure that entries filed reflect the correct tariff treatment.
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