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In a July 23, 2026 Memorandum, President Trump announced the final tariff rates for the 60 countries included in USTR’s Section 301 investigation into those countries’ efforts to prohibit importation of goods made with forced labor. The duties went into effect at 12:01 a.m. eastern time on July 24, 2026, with an exception for goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern time on July 24, 2026, and entered for consumption or withdrawn from warehouse for consumption before 12:01 a.m. eastern time on July 28, 2026. The 60 investigated countries comprise over 99% of U.S. imports.
The USTR determined to impose the following tariff rates on the investigated countries (see the Memorandum and USTR’s Notice of Action for full list of countries):
- 10%: Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, the United Kingdom, and Trinidad and Tobago.
- 10%, net of MFN rate (MFN rate plus 301 rate shall equal 10%, and if MFN rate is already at least 10%, then 301 rate shall equal zero): European Union and Taiwan
- 12.5%, net of MFN rate (MFN rate plus 301 rate shall equal 12.5%, and if MFN rate is already at least 12.5%, then 301 rate shall equal zero): Japan, Korea, and Switzerland
- 12.5%: all other investigated countries
In addition to the above tariffs, USTR has determined to establish tariff-rate quotas for Bangladesh, Cambodia, Indonesia, and Malaysia to encourage their importation of textile goods from the U.S.
There are numerous exemptions to the above tariffs, including for certain agricultural products, semiconductor equipment, pharmaceuticals, and others. Some products are fully exempt, while others are exempt depending on the country of origin. There are also exemptions for metals already subject to Section 232 duties and vehicle parts that receive special tariff treatment under the United States-Mexico-Canada Agreement (USMCA). The Memorandum’s Annex and CBP’s CSMS # 69326983 provide further guidance on the implementation of these new duties and exemptions.
The Section 301 forced labor tariffs took effect as the administration’s Section 122 tariffs expired this morning. The current Section 301 forced labor rates are identical (or nearly identical) to the Section 122 rates, but once the ongoing Section 301 structural excess capacity investigation concludes, key trading partners could see a substantially higher combined Section 301 tariff rate.
Assuming the Section 301 tariffs survive legal challenge, they are expected to provide a more stable path for the Trump administration to further its tariff policies than either IEEPA or Section 122. Section 301 of the Trade Act of 1974 contains the congressional authorization for tariffs that IEEPA lacks, and USTR’s actions taken under Section 301 terminate after four years, unless extended following a request for continuation. While the Section 301 action is in place, USTR can modify or terminate it in accordance with the Trade Act of 1974.
Braumiller Law Group will monitor Section 301 forced labor tariff implementation, as well as the ongoing Section 301 structural excess capacity investigation, and share pertinent updates as they become available.
Braumiller Law Group will provide further updates on the proposed tariffs as they become available.
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