As of May 2026, USTR has an unusually large and aggressive portfolio of active Section 301 investigations spanning dozens of trading partners and covering issues from manufacturing overcapacity to forced labor, digital services taxes, semiconductor dominance, and geopolitical trade abuses. The current wave is principally driven by the Trump Administration's use of Section 301 as a replacement vehicle for IEEPA tariffs following the Supreme Court's invalidation of the IEEPA-based "reciprocal tariffs."

USTR Ambassador Jamieson Greer has explicitly committed to an accelerated investigation timeline with the goal of having Section 301 tariffs in place before the temporary Section 122 bridge tariffs expire on July 24, 2026.

The current USTR Section 301 portfolio as of May 2026 consists of 13 active or recently completed proceedings, plus two pending petitions and several anticipated future investigations.

Group 1: New 2026 Mega-Investigations (Highest Priority)

  • Structural Excess Capacity in Manufacturing — Initiated March 11, 2026, targeting 16 economies (including China, EU, Japan, India, Mexico, Vietnam, and South Korea). Covers steel, semiconductors, EVs, and chemicals. Hearings concluded May 8, 2026; determination expected by July 24, 2026.

  • Failure to Enforce Forced Labor Prohibitions — Initiated March 12, 2026, targeting 60 economies representing over 99% of U.S. imports. Hearings concluded May 1, 2026; action expected on or before July 24, 2026.

Group 2: Ongoing Single-Country or Sector-Specific Investigations

  • China Semiconductors — Determination issued December 2025. Tariffs currently 0%, with an increase scheduled for June 23, 2027.

  • China Phase One Agreement — Initiated October 24, 2025; currently in the post-hearing determination phase.

  • Brazil (digital trade, tariffs, IPR, etc.) — Initiated July 15, 2025; currently in the post-hearing

    phase.

  • Nicaragua (labor / human rights) — Determination issued December 2025. Tariff schedule:

    0% (2026), 10% (2027), 15% (2028).

  • China Maritime / Shipbuilding — Fees suspended through November 9, 2026, following a U.S.-China trade deal.

Group 3: Legacy Investigations

  • Digital Services Taxes (DSTs) — Renewed February 2025 against France, Austria, Italy, Spain, Turkey, UK, and Canada. Under review for potential formal Section 301 action.

  • EU Large Civil Aircraft (Airbus) — Active; tariffs remain in force on EU goods.

  • China Forced Tech Transfer — Ongoing enforcement of original Section 301 tariffs (Lists 1–4).

  • Vietnam Currency Practices — Status is "dormant/unresolved," though a bilateral agreement was signaled.

  • Vietnam Timber — Resolved by bilateral agreement; effectively closed.

  • EU Beef — Active; managed through negotiated tariff-rate quotas.

Pending and Anticipated Actions

  • Pending petitions — Korea's Coupang data practices and Mexico's seasonal agricultural products.

  • Anticipated investigations — USTR has signaled potential future investigations into pharmaceutical pricing, digital protectionism (EU/Canada), and a Vietnam IP investigation.

Where countries may become subject to the multiple 301 orders, tariffs would overlap (i.e., “stack”).

The administration has adopted an accelerated procedural timeline so that the new 301 measures are in place before the Section 122 "bridge" tariffs expire on July 24, 2026.

Posted
AuthorMatt Nakachi