The Office of the U.S. Trade Representative (USTR) has taken final action to impose Section 301 tariffs on 60 economies for failing to adopt and effectively enforce a ban on imports made with forced labor. The action follows two rounds of public hearings and more than 2,100 public comments, and covers roughly 99.4% of U.S. imports.
Tariff Rates
USTR has set two headline duty rates based on each economy’s forced-labor import posture:
- 10% for trading partners that have committed to, or partially adopted, a forced-labor import prohibition (including through Agreements on Reciprocal Trade);
- 12.5% for trading partners that have not adopted such a prohibition.
Certain products of the European Union, Taiwan, Japan, Korea, and Switzerland carry a rate of 10% or 12.5% net of the Most-Favored-Nation (MFN) rate, rather than the flat rate applied to other economies. Full country-by-country and product-level detail is in the Federal Register notice.
Effective Date and Transit Exception
The tariffs apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET, Friday, July 24, 2026.
A narrow exception applies to cargo already in transit: goods loaded onto a vessel for the final leg of the voyage before that deadline are not subject to the new duty if they are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. ET, Tuesday, July 28, 2026.
What’s Exempt
USTR has excluded several categories from the new duties, including:
- Informational materials, donations, and accompanied baggage;
- Articles and parts already subject to Section 232 tariffs; and
- Raw materials and other products where the additional duty could cause domestic supply shortages, economy-wide disruption, or where sufficient U.S. or alternative-source supply doesn’t exist.
A complete list of exempted products and HTS numbers is included in the Federal Register notice.
How This Fits with Section 122
This action is separate from, but related to, the Section 122 global import surcharge, which expires July 24 — the same day these Section 301 duties take effect. For background on that transition, see Alba’s Section 122 Expires July 24article.
What Importers Should Do Now
- Identify whether your suppliers’ countries of origin fall within the 60 covered economies, and confirm which rate tier applies;
- Check loading and entry dates for any shipments currently in transit against the July 24 / July 28 transit-exception window;
- Review the Federal Register notice’s exemption list for any HTS numbers relevant to your imports; and
- Flag affected entries to your customs broker now to avoid unexpected duty assessments at time of entry.
Questions about how this action affects your imports?
ASK Alba™, our trade compliance team, can help you assess exposure and confirm entry timing.
Get in touch here.
References
