On July 23, 2026, the Office of the U.S. Trade Representative announced final action in its Section 301 investigations into forced labor, imposing new tariffs on imports from 60 economies. U.S. Customs and Border Protection issued implementing guidance the same day (CSMS # 69326983), and the additional duties took effect at 12:01 a.m. EDT on July 24, 2026, immediately following the expiration of the temporary Section 122 duties.

Under the two-tiered structure, most goods from economies that impose a forced-labor import prohibition, have committed to do so under an Agreement on Reciprocal Trade, or maintain a partial prohibition regime are subject to an additional 10 percent duty. Most goods from all other investigated economies are subject to an additional 12.5 percent duty. Certain products of the European Union, Taiwan, Japan, Korea, and Switzerland are subject to rates of 10 percent or 12.5 percent net of the most-favored-nation rate, as detailed in the Federal Register notice.

The action follows USTR's June 2026 proposal, two rounds of public hearings, and more than 2,100 public comments. The measures cover the substantial majority of U.S. imports but include exemptions set out in the notice's annexes, such as certain agricultural products, minerals, pharmaceutical goods, aviation parts, and goods already subject to separate Section 232 tariffs. Goods loaded and in transit before 12:01 a.m. EDT on July 24, 2026, and entered before 12:01 a.m. EDT on July 28, 2026, are not subject to the additional duty.

Litigation challenging the new tariffs is expected to be filed rapidly.

This post is provided for informational purposes only to report on this development and does not constitute legal advice.

Posted
AuthorMatt Nakachi