Reviews could lead to tariffs or trade restrictions affecting dozens of economies
The Office of the United States Trade Representative (USTR) has launched two new investigations under Section 301 of the Trade Act of 1974, targeting forced labor practices in global supply chains and excess manufacturing capacity that may distort international markets.
The investigations will examine whether certain foreign policies or practices burden or restrict U.S. commerce and could lead to tariffs, trade restrictions, or other enforcement measures if violations are confirmed.
Section 301 investigations allow the United States to take action against foreign practices deemed unreasonable or discriminatory and that burden U.S. commerce.
Together, the investigations could have broad implications for global supply chains and import compliance.
USTR Section 301 Investigation 1:
Forced Labor in Global Supply Chains
USTR has initiated 60 Section 301 investigations to determine whether U.S. trading partners have failed to adequately address forced labor connected to goods entering global supply chains.
The investigations will examine whether governments have taken sufficient action to prohibit imports produced with forced labor or enforce labor protections within their export sectors.
The review covers 60 economies across Europe, Asia, and the Americas, including major trading partners such as:
- China
- The European Union
- Canada
- Mexico
- India
- Vietnam
- Brazil
- Japan
If USTR determines that these practices constitute unreasonable or discriminatory acts under Section 301, the United States could impose tariffs or other trade measures on imports from affected economies.
Key Timeline
- Public comments due: April 15, 2026
- Public hearings: April 28 – May 1, 2026
USTR Section 301 Investigation 2:
Excess Manufacturing Capacity
USTR also announced a separate Section 301 investigation examining excess manufacturing capacity in certain economies.
The investigation will assess whether government policies or industrial strategies are contributing to global overproduction that distorts markets and disadvantages U.S. manufacturers.
Economies included in this investigation are:
- China
- European Union
- Singapore
- Switzerland
- Norway
- Indonesia
- Malaysia
- Cambodia
- Thailand
- South Korea
- Vietnam
- Taiwan
- Bangladesh
- Mexico
- Japan
- India
USTR will evaluate whether these practices create structural market distortions that burden U.S. commerce, which could result in future trade enforcement actions or tariffs.
Key Timeline
- Public comments due: April 15, 2026
- Public hearing: May 5, 2026
Implications for Importers and Supply Chains
These investigations reflect increasing U.S. scrutiny of global supply chains and trade practices.
Importers should monitor developments closely, particularly if their sourcing involves countries included in either investigation.
Potential impacts may include:
- New Section 301 tariffs or trade restrictions
- Increased forced labor enforcement across supply chains
- Greater due diligence expectations for importers
- Potential sourcing and duty exposure risks
Companies may wish to evaluate supplier networks, country-of-origin exposure, and potential tariff risk as the investigations progress.
How Alba Can Help
The Alba Group helps importers navigate evolving trade enforcement measures and supply chain compliance requirements.
Our team supports clients by:
- Monitoring tariff exposure and trade policy developments
- Conducting import and sourcing risk assessments
- Advising on classification, origin, and duty mitigation strategies
- Supporting customs compliance and supply chain due diligence
Companies with exposure to countries included in the investigations may wish to review their sourcing strategies and compliance programs as the review process moves forward.
For additional guidance, contact the Alba team, https://albawheelsup.com/contact.
