USTR proposed additional Section 301 duties of 10% or 12.5% on products from 60 economies tied to forced-labor import prohibitions and enforcement. Written comments are due July 6, 2026, and hearings begin July 7. The proposal is not final, but importers should review HTS codes, country of origin, supplier documentation, UFLPA risk, and tariff-stacking exposure now.
On June 2, 2026, the Office of the United States Trade Representative announced determinations and proposed action in 60 Section 301 investigations related to whether trading partners have failed to impose or effectively enforce prohibitions on imports made with forced labor. USTR’s press release says written comments are due July 6, 2026, with hearings starting July 7.
The proposal matters because it can add a new duty layer on top of ordinary MFN duty, China Section 301 duties, Section 232, anti-dumping or countervailing duties, and existing forced-labor detention risk under the UFLPA. For importers, the July comment window is a trigger to review the import file before the government finalizes the action.
What USTR proposed
USTR says it determined that the failure of the investigated economies to impose and effectively enforce forced-labor import prohibitions is actionable under Section 301. As a proposed response, USTR described additional duties on products of the investigated economies, subject to exceptions in the Federal Register notice.
| Proposal element | What importers should know |
|---|---|
| Scope | 60 investigations covering economies that USTR says failed to impose and/or effectively enforce prohibitions on forced-labor goods. |
| Proposed rate | Generally 10% for economies with some prohibition or commitment, and 12.5% for other economies, subject to USTR’s final action and exceptions. |
| Key dates | Request-to-appear deadline: June 22, 2026. Written comments: July 6, 2026. Hearings: July 7, 2026. |
| Textiles | USTR also described a textile mechanism that could allow certain volumes of apparel and textile imports from certain economies at a reduced Section 301 tariff rate. |
This is a proposed action, not a final tariff schedule. Do not update customer pricing, sourcing, or declared origin solely on headlines. Start with the entry file: HTS, origin, supplier documents, and any existing forced-labor due-diligence records.
Which importers should care first?
The broad proposal means importers should not treat this as only a China or apparel issue. The first review should focus on lanes where forced-labor scrutiny, tariff stacking, and country-of-origin documentation already matter.
- Textiles and apparel importers sourcing from multiple Asia, Latin America, or Middle East economies.
- Electronics, components, batteries, and solar-adjacent goods with complex supplier chains.
- Food, consumer goods, and housewares importers using contract manufacturers or trading companies.
- Importers that changed country-of-origin claims after tariff increases or forced-labor enforcement actions.
- Foreign importers of record whose supplier documents, bond, IOR structure, and broker files may face higher CBP scrutiny.
What to review before July 6
1. HTS code and country-of-origin support
List the HTS codes, manufacturing countries, supplier names, and entry dates for affected lanes. If a product’s declared origin changed after tariffs increased, confirm the origin analysis is documented and not just tariff-driven.
2. Supplier documentation and forced-labor due diligence
Review purchase orders, production records, supplier affidavits, factory locations, and any forced-labor questionnaires. UFLPA detention risk and Section 301 forced-labor duties are different tools, but the documentation overlap is significant.
3. Tariff-stacking exposure
A 10% or 12.5% layer can be the difference between a viable and unviable margin if the product already carries Section 301, Section 232, AD/CVD, or a temporary surcharge. Model the stack by HTS code, not by product category. See our Tariff Stacking Report 2026 for the mechanics.
4. Textile and apparel volume planning
Because USTR referenced a possible textile mechanism, apparel and textile importers should separate products by HTS chapter, supplier economy, origin support, and shipment timing. If a reduced-rate mechanism becomes final, the importer that already has clean data can react faster.
5. Comment strategy
Importers considering a comment should be specific. Useful comments usually identify affected HTS codes, sourcing countries, operational impact, compliance controls, and proposed alternatives. For legal submissions, coordinate with trade counsel; for entry data and duty modeling, your broker should have the import-file facts ready.
Review forced-labor tariff exposure before comments close.
Send us your affected HTS codes, supplier countries, and recent entries. We can help map where Section 301 forced-labor proposals, UFLPA documentation, origin support, and existing tariff layers intersect.
- HTS and origin review by supplier lane
- Tariff-stacking model for 10% and 12.5% scenarios
- Forced-labor documentation checklist
- Broker-file review before CBP scrutiny
How this differs from UFLPA detention risk
The UFLPA is a detention-and-admissibility regime focused on goods with a Xinjiang or forced-labor nexus. The Section 301 proposal is a trade-remedy duty proposal tied to foreign economies’ forced-labor import prohibition and enforcement regimes. They are not the same program, but they can point to the same operational problem: importers need better supplier-chain evidence.
If your company already has a UFLPA documentation package, review whether it also supports origin, supplier identity, and tariff-stacking decisions. If it does not, the import file may still be exposed even if a shipment has not been detained.
Frequently asked importer questions
Are these forced-labor Section 301 duties final?
No. USTR proposed the responsive action and requested comments. The rates, product scope, exceptions, and timing can change before final action.
Do the proposed duties only affect China?
No. USTR identified 60 investigations. The list includes many economies beyond China, including several countries used in apparel, consumer goods, electronics, and component supply chains.
Should I change sourcing before July 6?
Not based on the proposal alone. First confirm which HTS codes and supplier countries are actually exposed, what existing duty layers apply, and whether the alternative source has better documentation and origin support.
What should I ask my broker for?
Ask for a list of affected entries by HTS code, country of origin, supplier, Chapter 99 duty line, existing duty layers, and any UFLPA or forced-labor documentation already on file. That is the base file for comments, planning, or internal review.
The bottom line
The July 6 comment deadline is not only a legal-calendar event. It is a practical deadline to find out whether a new 10% or 12.5% forced-labor-related duty layer could hit your lanes and whether your origin and supplier documentation can survive review.
Importers that wait for the final notice may still have time to comply, but they will be slower to price, source, comment, or adjust shipment timing. Use the comment window to turn scattered entry files into a defensible import plan.
Sources: USTR, “USTR Makes Findings and Proposes Action in 60 Section 301 Investigations Relating to Failures to Take Action on Trade in Forced Labor Goods,” June 2, 2026; Federal Register, “Notice of Determinations and Request for Comments Concerning Actions in Section 301 Investigations,” June 5, 2026. This article is operational guidance for importers and is not legal advice.