Section 301 Forced Labor Investigations: What the 60 New USTR Findings Mean for Importers

On June 2, USTR made findings in 60 Section 301 investigations and proposed additional duties on goods from 60 economies. China, Vietnam, Cambodia, Thailand, Malaysia, and most of our largest trading partners in Asia.

If you source from any of those markets, pay attention.

Section 301 of the Trade Act of 1974 gives USTR authority to respond to foreign acts, policies, or practices that burden or restrict U.S. commerce. Different mechanism than IEEPA, which is the emergency authority the Supreme Court struck down in February.

That distinction matters more than people think.

Section 301 has a process: investigation, public comment, hearing, finding, proposed action. USTR opened these 60 investigations in March, held hearings, took nearly 500 comments, heard 60 witnesses. They did the work. Legally, that makes this much harder to challenge than IEEPA. The IEEPA decision did not end the tariff conversation, and second-half plans built on that assumption are vulnerable.

On June 15, 2026, the Supreme Court denied review in HMTX Industries, LLC v. United States. That means the lower court ruling stands. The Federal Circuit’s decision upholding USTR’s authority for the Section 301 List 3 and List 4A tariffs remains final. The tariffs stay in place, and the main importer challenge is over.

The investigation found that all 60 economies failed to impose or effectively enforce a prohibition on the importation of goods produced with forced labor. Based on that, USTR is proposing:

• 10% additional duties on goods from economies with a forced labor import prohibition, or that have committed to one under USMCA or Reciprocal Trade Agreements
• 12.5% on everyone else, which is the majority of Asian sourcing markets
• A textile mechanism letting certain apparel and textile imports come in at a reduced Section 301 rate

The 10% tier is Canada, Mexico, the EU. The 12.5% tier is China, Vietnam, Cambodia, Thailand, Malaysia, Bangladesh, India, and most of the rest.

These rates stack on top of existing Section 232 duties (steel, aluminum) and existing Section 301 duties (China-specific). Run your landed cost numbers before you assume you know what this does to your margins. Most of the spreadsheets we see from new clients are wrong about this.

June 22: deadline to request to appear at the public hearing

July 6: written comment deadline (comments.ustr.gov)

July 7: public hearing in Washington

If you have product-specific relief to argue, a classification issue, or a documented supply chain impact, the comment window is where it goes on the record. After July 6 it’s too late.

Pull your import manifest with your licensed customs broker. Know your HTS classifications for each affected country and what your total duty exposure looks like at the proposed rates. If you haven’t recalculated landed costs since IEEPA was vacated, do it again. The picture keeps changing.

The real question isn’t whether these duties get challenged. It’s whether your supply chain can absorb them, or route around them, if they go into effect.

If the answer is “I don’t know,” that’s the work this week.

Sources: USTR Press Release, June 2, 2026 | Federal Register Notice FR-2026-06-05 | Public Comment Docket

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