Here Come the Section 301 Investigations

Mar. 12, 2026
By: Frederic D. Van Arnam, Jr.

On March 11th, Ambassador Greer of the Office of the U.S Trade Representative announced that Section 301 investigations have been initiated against the following:

• the EU
• Singapore
• Switzerland
• Norway
• Indonesia
• Malaysia
• Cambodia
• Thailand
• South Korea
• Vietnam
• Taiwan
• Bangladesh
• Mexico
• Japan
• India
• China (again)

Section 301 investigations look at the practices of foreign countries and if found to create an unreasonable or discriminatory burden on or otherwise restrict U.S. trade, then the U.S. can attempt to remediate those unjustified practices via the imposition of tariffs. In the case of the countries listed above, the U.S. will be eyeing structural excess capacity and overproduction in various manufacturing sectors to see if such acts or practices are damaging U.S. production.

The U.S. has requested consultation with those countries as a first step in these investigations. The next step will be the public comment period. Ambassador Greer stated that the window will open on March 17th, and close on April 15th. During this period, stakeholders may submit written comments in favor or against the proposed actions and can request an opportunity to be heard at a public hearing scheduled for May 5th. Those interested in appearing not only need to request that opportunity before April 15th but must also submit a summary of their anticipated testimony by then as well.

As mentioned above, it seems very likely that the duty rates that will be assigned to these countries will mirror the rates that those countries previously negotiated with the U.S. (for those countries that had done so), or the IEEPA rates implemented when the initial 90-day pause was lifted. And if the current China Section 301 duties serve as an example, these new Section 301s will stack on top of other duties.

Do not hesitate to contact any attorney at Barnes, Richardson & Colburn, LLP if you have questions about duties, duty refunds, or the latest new duties being contemplated.