The Office of the U.S. Trade Representative (USTR) has issued a Notice of Determinations and Request for Comments in its Section 301 investigations concerning various economies’ alleged failure to impose and effectively enforce prohibitions on imports of goods produced with forced labor. Although ostensibly about forced labor enforcement, the new duties are in reality a replacement for the Section 122 duties that will expire in July.

USTR determined that all 60 investigated economies are engaging in actionable conduct under Section 301. As proposed actions, USTR is recommending imposing additional duties on products from the investigated economies, subject to exclusions in Annex A. The Annex excludes a variety of articles from the proposed action, including certain agricultural products, raw materials, critical inputs, and other products.

USTR proposes imposing 10% additional duties on 14 selected economies that USTR views as having relatively stronger forced-labor import prohibition regimes. All other investigated economies would be subject to a proposed 12.5% rate. Please see below for the economies in each group.

The proposed action also would not cover informational materials, donations, accompanied baggage; all articles and parts of articles that are subject to section 232 tariffs; USMCA-compliant goods of Canada or Mexico; and textiles and apparel articles that enter duty-free as a good of Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, or Nicaragua under the Dominican Republic–Central America Free Trade Agreement (CAFTADR).

The proposed schedule for comments is as follows:

• Requests to appear at the hearing are due June 22, 2026;
• Written comments are due July 6, 2026;
• Public hearing will be held July 7, 2026; and
• Post-hearing rebuttal comments are due five days after the last day of the public hearing.

Selected Countries (10%)

Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, European Union, Guatemala, Indonesia, Malaysia, Mexico, Pakistan, Taiwan, United Kingdom.

All Others (12.5%)

Angola, Australia, The Bahamas, Bahrain, Brazil, Chile, People’s Republic of China, Colombia, Costa Rica, Dominican Republic, Egypt, Guyana, Honduras, Hong Kong, China, India, Iraq, Israel, Japan, Jordan, Kazakhstan, Kuwait, Libya, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, South Korea, Sri Lanka, Switzerland, Thailand, Trinidad and Tobago, Türkiye, United Arab Emirates, Uruguay, Venezuela, Vietnam.

USTR is accepting written comments until July 6 and will hold a hearing on July 7. Requests to appear at the hearing, along with a summary of the proposed testimony, are due June 22.

Taft will continue to monitor the proceedings and update the team as USTR moves toward any final action.