New hearings and expanded WRO activity point to a global shift in enforcement—importers face layered tariff and detention risk.
Section 301 Hearings Begin as Trade Policy Reshapes
The Office of the U.S. Trade Representative (USTR) is launching new Section 301 hearings beginning April 28, 2026, at the U.S. International Trade Commission (USITC).
The hearings will focus on:
- Forced labor (April 28)
- Excess capacity (May 5)
These proceedings are expected to shape the next phase of U.S. tariff policy following IEEPA changes.
Section 301: A Long-Term Tariff Mechanism
Unlike temporary tariff measures, Section 301 actions:
- Do not expire
- Can be applied broadly across industries and countries
- Will likely stack on top of existing tariffs, including Section 122
This creates a more permanent and complex tariff environment.
Enforcement Is Expanding Beyond China
At the same time, CBP is broadening forced labor enforcement geographically.
New Withhold Release Orders (WROs) now target:
- Coffee from Mexico
- Bicycle parts from Taiwan
- Garments from Mauritius
This signals a clear shift:
Forced labor enforcement is no longer China-centric
Dual Exposure: Tariffs + Detentions
Section 301 actions tied to forced labor will not replace existing enforcement tools like UFLPA—they will layer on top of them.
Importers may now face:
- UFLPA detentions
- Section 301 tariffs
- Expanded WRO scrutiny
All on the same shipment.
What Importers Should Do Now
Importers should immediately:
- Map sourcing across all countries—not just China
- Identify exposure to high-risk sectors (steel, agriculture, components)
- Monitor Section 301 hearing outcomes and rebuttal timelines
- Strengthen forced labor due diligence across suppliers
How Alba Can Help
Alba helps importers:
- Assess exposure across tariff and enforcement regimes
- Strengthen compliance and supplier vetting programs
- Navigate overlapping risks across UFLPA, WROs, and Section 301
