Labor & Employment Law Daily Wrap Up, ECONOMIC NEWS—USTR proposes new tariff actions, this time related to alleged trade in forced labor goods, (Jun 3, 2026)

By Brandi O. Brown, J.D.

Switching tactics, the Trump administration is now proposing tariffs on trading partners based on allegations they failed to take appropriate action on trade in forced labor goods.

Yesterday, the United States Trade Representative (USTR) announced that it has determined, under Section 301 of the Trade Act of 1974, that the acts, policies, and practices of 60 separate economies—related to their alleged failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor—are unreasonable and burden or restrict U.S. commerce, and are actionable.

USTR’s report, Acts, Policies, and Practices of Various Economies Related to the Failure to Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced with Forced Labor, names multiple countries and economies that it concludes have either failed to impose and/or failed to effectively enforce a forced labor import prohibition. Among those 54 listed economies alleged to have failed to impose and effectively enforce this prohibition are the United Kingdom, China, Australia, Israel, Japan, New Zealand, South Korea, and Norway. The six economies alleged to have failed to effectively enforce a prohibition are Canada, Ecuador, the European Union, Indonesia, Mexico, and Pakistan.

Public comment and hearings. As a result of its determinations, USTR has proposed responsive action for public comment. It is publishing a notice in the Federal Register setting out the actionability determination and its proposed actions. USTR will also hold hearings and has announced a docket for requests to appear at the public hearings to be held in connection with the investigations.

Proposed duties and exceptions. USTR is proposing additional duties on all products of the investigated economies, with an extensive list of exceptions identified in Annex A to the Federal Register notice, which include many identified products that could be grouped under general categories such as agricultural and food products (such as meat products, fruits and vegetables, nuts and seeds, and coffee, tea, and spices); raw materials and natural resources; chemicals and petrochemicals; pharmaceutical and medical products; fertilizers; plastics, polymers, and rubber products; metals and alloys; energy, fuels, and byproducts; and civil aircraft-related parts.

Rates. For economies that impose a forced labor import prohibition, which have committed to impose and enforce such a prohibition through an Agreement on Reciprocal Trade, or economies that have imposed a partial regime with the effect of preventing the importation of certain forced labor goods, USTR proposes 10 percent as the rate of additional duties. For all other economies, USTR proposes 12.5 percent as the rate of additional duty. USTR has also proposed a textile mechanism that would allow for a certain volume of apparel and textile imports from certain economies to enter the United States at a reduced Section 301 tariff rate.

Requests to appear at the hearings, along with a summary of the testimony, are due by June 22, 2026. Written comments are due by July 6, 2026. Hearings will start on July 7, 2026.

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