ARTICLE
28 July 2026

New Forced Labor Tariffs Imposed On 60 U.S. Trading Partners

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Wiley Rein

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The Office of the U.S. Trade Representative has released its final tariff action under Section 301 investigations into forced labor trade practices by 60 U.S. trading partners, imposing duties of 10% to 12.5% that took effect July 24, 2026. The determination includes varying duty structures for different trading partners, with some duties stacking on existing rates while others are capped at combined thresholds, alongside hundreds of product-specific exclusions ranging from agricultural goods to semiconduct
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On July 23, 2026, the Office of the U.S. Trade Representative (USTR) released the final tariff action in its investigations under Section 301 of the Trade Act of 1974 into whether trade practices maintained by 60 U.S. trading partners relating to forced labor are unreasonable and burden or restrict U.S. commerce. These partners collectively account for more than 99% of imports into the United States.

Duties of 10% to 12.5% imposed under the final action went into place at 12:01 a.m. on July 24, 2026, just as pre-existing 10% global duties under Section 122 of the Trade Act of 1974 expired. There is a short grace period (lasting until July 28) for goods that were already en route to the U.S. on their final mode of transit before the Section 301 action took effect. 

USTR originally proposed to impose 10% additional import duties on 14 of the 60 investigated trading partners and 12.5% on the rest, and proposed that these duties would stack on top of “standard” duty rates, i.e., those rates that would apply absent any Executive tariff action. In the final determination, USTR shifted more partners to the 10% duty rate and provided for duties not to stack in certain cases. In other words, if a tariff would otherwise apply to the product, the Section 301 action imposes a tariff up to 10% or 12.5% for certain partners. USTR’s final decision on tariff rates by trading partner is as follows:

  • A 10% duty (which will stack on top of existing “standard” duty rates) for 17 trading partners (Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, the United Kingdom, and Trinidad and Tobago).
  • A combined 10% duty, net of duties imposed under the Section 301 action and existing “standard” duty rates, for goods of the EU and Taiwan with standard duty rates less than 10%.
  • A combined 12.5% duty, net of duties imposed under the Section 301 action and existing “standard” duty rates, for goods of Japan, Korea, and Switzerland with standard duty rates less than 10%.
  • A 12.5% duty (which stacks on existing standard duty rates) for all other investigated trading partners, including China and Vietnam.

USTR also intends to develop special tariff rate quotas for certain textile products from Bangladesh, Cambodia, Indonesia, and Malaysia.

Not all products are covered by the duties. USTR’s original proposal broadly exempted products already subject to Section 232 national security duties, USCMA-compliant goods, certain textiles entered under the Dominican Republic Central America Free Trade Agreement (DR-CAFTA), and goods otherwise not subject to the expiring Section 122 duties, including items for civil aircraft use and pharmaceutical products and ingredients. USTR has not removed any products from the originally proposed exclusion list, other than certain chemicals and chemical products when imported for non-pharmaceutical applications. The final determination incorporates several hundred new exclusions, which apply to:

  • Certain animal products; certain seeds; and certain vegetable products
  • Certain sugar and sugar containing products
  • Unflavored instant coffee
  • Certain fertilizer inputs and pesticide inputs
  • Certain animal hides and leather
  • Certain wood products
  • Vanadium oxides and hydroxides
  • Pig iron
  • Certain ferrous inputs and waste
  • Certain aluminum scrap waste
  • Aluminum hydroxide
  • Ash containing precious metals or precious metal compounds
  • Certain battery waste and scrap
  • Certain semiconductor manufacturing equipment
  • Certain pharmaceuticals and pharmaceutical ingredients
  • Worked shell
  • Worn clothing and
  • Certain antiques, collectibles, and art

Beyond the general exclusions, there are also some economy-specific exemptions for listed products from the UK, EU, Switzerland, Malaysia, Cambodia, Guatemala, El Salvador, Argentina, Bangladesh, Taiwan, Indonesia, Ecuador, and Jordan.

Annex I to USTR’s final notice lays out the formal implementing language that will be included in the U.S. tariff schedule. Annex II (which begins at page 137 of the PDF of the determination notice) provides lists of exempted tariff codes and any limits on those exemptions. Table A provides generally available exclusions, with notes as to whether only pharma or civil aircraft goods are exempt. Tables B – O then provide country-specific exclusions, as well as exclusions for textile and apparel goods entered under DR-CAFTA.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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