USTR imposes Section 301 tariffs on all products from 60

Cresthaven AnalyticsIntelligence Brief

Headline

USTR imposes Section 301 tariffs on all products from 60 economies over forced labor import prohibition failures

Executive Summary

USTR published a notice on July 28, 2026 imposing Section 301 tariffs on products from 60 investigated economies, effective for entries on or after 12:01 a.m. eastern time on July 24, 2026. Economies that have imposed a forced labor import prohibition, committed to one through an Agreement on Reciprocal Trade, or imposed a qualifying partial regime face a 10 percent duty rate. All others face 12.5 percent.

Bottom Line

USTR imposes Section 301 tariffs on all products from 60 economies, at 10 percent for economies with qualifying forced labor import regimes and 12.5 percent for all others, with duties applicable to entries on or after 12:01 a.m. eastern time on July 24, 2026. The 54 economies found to have failed to impose and effectively enforce a forced labor import prohibition, and the six found to have failed to effectively enforce an existing prohibition, are each subject to the applicable rate on all products, with exemptions as provided in Annexes I and II of the notice. Cresthaven reading: importers of record with supply chains touching any of the 60 covered economies face an immediate duty exposure on entries from July 24, 2026 forward, with the applicable rate determined by each economy's forced labor regime status as assessed by USTR.

Key Regulatory Signals

Retroactive Effective Date Precedes Publication: The additional duties apply to products entered for consumption on or after 12:01 a.m. eastern time on July 24, 2026, four days before the July 28 Federal Register publication date. Goods loaded onto a vessel and in transit before 12:01 a.m. on July 24, 2026, and entered before 12:01 a.m. on July 28, 2026, are exempt from the additional duty.
Two-Tier Duty Structure Based on Forced Labor Regime Status: Economies that have imposed a forced labor import prohibition, committed to one through an Agreement on Reciprocal Trade, or imposed a partial regime with the effect of preventing importation of certain forced labor goods are subject to a 10 percent Section 301 duty rate, net of the product's most-favored-nation duty for specific economies. All other investigated economies face a 12.5 percent rate, also net of MFN duty for specific economies.
54 Economies Found to Have Failed to Impose and Enforce a Prohibition: USTR's June 2, 2026 determination identified 54 economies as having failed to impose and effectively enforce a forced labor import prohibition, including China, India, Japan, the United Kingdom, South Korea, Vietnam, and Brazil, among others. Six additional economies, including Canada, the European Union, Mexico, and Indonesia, were found to have failed to effectively enforce an existing prohibition.
TRQs for Four Textile Economies Announced but Not Yet Established: USTR has determined to establish, when feasible, tariff-rate quotas for Bangladesh, Cambodia, Indonesia, and Malaysia, based on each economy's importation of U.S. inputs, to encourage importation of U.S. cotton and textile goods. Until the TRQs are established, the 10 percent Section 301 rate applies to imports of the specific textile and apparel of these four economies that the TRQs will cover. Cresthaven reading: importers of record sourcing from these four economies face the 10 percent duty rate on current entries, with the TRQ mechanism representing a prospective adjustment whose timing the source does not specify.

Regulatory Delta

USTR initiated these 60 investigations on March 12, 2026 and issued actionability determinations on June 2, 2026. This notice marks the first imposition of Section 301 duties targeting forced labor import prohibition failures across a broad, multi-economy scope.
The two-tier rate structure, 10 percent for economies with qualifying forced labor regimes, 12.5 percent for all others, introduces a compliance-based duty differentiation absent from prior Section 301 tariff waves targeting China or specific trade practices.
This action runs alongside the existing forced labor import ban under U.S. customs law, which prohibits importation of goods made with forced labor. The Section 301 tariff operates as a separate, additional layer on top of that existing prohibition.

Materiality Classification

HIGH — Final Section 301 tariff action with a retroactive effective date of July 24, 2026, imposing immediate duty obligations on importers of record sourcing from 60 economies, covering a broad regulated population across all product categories.

Intelligence Outlook

Monitor USTR for publication of the TRQ establishment notices for Bangladesh, Cambodia, Indonesia, and Malaysia, and for any amendments to Annexes I and II governing product exemptions under this action.