USTR Surprises Nobody, Recommends Forced Labor Tariffs for 60 Countries

Jun. 3, 2026
By: Hannah B. Kreinik

The U.S. Trade Representative posted a pre-publication notice on the results of the Section 301 forced labor investigation into sixty countries. To the surprise of nobody the USTR concludes that tariffs between 10% and 12.5% should be applied to 60 countries.

The notice explains that most countries in the investigation did not prohibit forced labor and that six countries that did impose such bans failed to sufficiently enforce the prohibitions. Finally, the notice concludes that some select countries, like the UK, Canada, and EU, should be subject to a 10% duty, while the other remaining countries should be subject to a 12.5% tariff. Any parties wishing to submit a request to appear at the hearings should file by June 22^nd, and parties wishing to submit written comments should file by July 6^th.

This should not come as a surprise to importers, as President Trump himself has specifically spoken on “replacing” the IEEPA tariffs rebuffed by the Supreme Court earlier this year (see our article on the decision here). With the United States aggressively enforcing its prohibition of imports using forced labor over the last several years, the administration has come to see a lax attitude toward the use of forced labor as an issue of market manipulation.

Since President Trump and his administration have made clear that tariffs will be at least part of the answer to any trade issue and even some issues unrelated to trade. Therefore, in addition to the forced labor duties recommended by the USTR, importers should expect and prepare for Section 301 duties based on “global excess capacity” as well as other country-specific matters (see the new Brazil 301 discussion here).

Barnes, Richardson & Colburn attorneys are here to keep importers up to date on current tariffs and potential trade changes.