Share on LinkedInShare on LinkedIn

ARTICLE · 03 JULY 2026

Forced Labor Tariffs – Public Comments Due Next Week For USTR Section 301 Investigation

Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Contributor
Explore more from Benesch, Friedlander, Coplan & Aronoff LLP

The U.S. proposes implementing new tariffs in a two-tier structure. Imports from tier one countries with forced labor import prohibitions may face additional 10% duties.

GlobalInternational Law
Jonathan R. Todd
Jonathan R. Todd
Vanessa I. Gomez
Vanessa I. Gomez
Ashley Corbin Rice
Ashley Corbin Rice
Author LinkedIn connections

Key Takeaways

  • The U.S. Trade Representative recently concluded its Section 301 investigation into forced labor concerns for imports from 60 countries.
  • The U.S. proposes implementing new tariffs in a two-tier structure. Imports from tier one countries with forced labor import prohibitions may face additional 10% duties. Imports from tier two countries without forced labor import prohibitions may face additional 12.5% duties.
  • U.S. importer action items are to consider submitting public comments by July 6, 2026, and maintaining strenuous supply chain planning, procurement cost awareness and import compliance functions.

U.S. importers have the opportunity to submit public comment on proposed tariffs that will utilize Section 301 as a means of addressing forced labor in global supply chains. Comments are due to the U.S. Trade Representative (“USTR”) by July 6, 2026. The USTR is focused on receiving input for a number of topics regarding the proposed tariffs including the duty rate

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

The Lindsey Graham Sanctions Act: What Businesses Need To Know About The New Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

Updates On Export Controls Impacting AI & Advanced Computing

The U.S. Department of Commerce's Bureau of Industry and Security issued guidance on May 31, 2026, clarifying licensing requirements for advanced computing items and AI technologies. The guidance maintains export restrictions for entities in certain countries while providing limited relief for data center operators, though questions remain about future regulatory direction. Companies must now strengthen their compliance programs and supply-chain due diligence as BIS continues to prioritize national security
GlobalInternational Law
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Article

New Tariffs And Import Bans: An Update On The U.S.-Canada “Trade War”

The U.S.-Canada trading relationship has reached a critical juncture as both nations implement escalating trade measures, with Canada's counter-tariffs taking effect and the United States responding with unprecedented import bans on Canadian alcoholic beverages, dairy products, and motorcycles. These actions mark a significant expansion of the Trump Administration's use of Section 338 of the Tariff Act of 1930, moving beyond additional tariffs to outright import restrictions. What does this escalation mean
GlobalInternational Law
Cassidy Levy Kent LLP
Cassidy Levy Kent LLP
Article

Update On CAPE Phase 3 Duty Refunds From U.S. Customs And Border Protection

U.S. Customs and Border Protection has announced that importers with court orders for IEEPA duty refunds on finally liquidated entries can begin filing for those refunds starting October 6, 2026, through the CAPE Phase 3 system. This development follows the Supreme Court's February 2026 decision striking down IEEPA tariffs and represents a critical step for importers seeking refunds on entries liquidated for more than 80 days.
United StatesInternational Law
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

Congress Passes New Russian Sanctions Bill Providing Additional Tariff Authority To Address Countries That Purchase Russian Energy, Facilitate Evasion Of Russian Sanctions

The U.S. House of Representatives has passed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, which directs the President to impose tariffs of up to 500 percent on Russian imports and up to 100 percent on imports from countries that are significant purchasers of Russian energy. The bill includes provisions for Presidential waiver authority and a five-year sunset clause...
GlobalInternational Law
Kelley Drye & Warren LLP
Kelley Drye & Warren LLP
Article

IEEPA Tariff Refunds: Critical Developments, Phase III Delays, And Action Steps For Importers

U.S. Customs and Border Protection has begun processing IEEPA tariff refunds through its CAPE system, but Phase III covering finally liquidated entries faces delays and requires court orders. With the Department of Justice appealing the universal refund order and class certification pending, importers with finally liquidated entries may need to file individual lawsuits at the Court of International Trade to preserve their claims before statutory deadlines expire.
United StatesInternational Law
Barnes & Thornburg LLP
Barnes & Thornburg LLP
Article

The Coming State-Law Litigation Wave Of 2026-27: “Subscription Trap” Class Actions

State-law class actions targeting automatic renewal and subscription practices are accelerating, creating significant litigation risk for companies that rely on recurring revenue models. Recent settlements demonstrate that even technical compliance failures can lead to seven-figure exposure, with California, Illinois, and Virginia statutes driving the most aggressive litigation.
United StatesConsumer Protection
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

DOJ Announces 2026 National Health Care Fraud Takedown: 455 Defendants Charged In $6.5 Billion Enforcement Action

The Department of Justice's 2026 National Health Care Fraud Takedown charged 455 defendants in connection with $6.5 billion in alleged fraud schemes, marking an unprecedented scale of enforcement action. This whole-of-government approach leverages advanced data analytics and international cooperation to combat healthcare fraud across Medicare, Medicaid, and other federal programs. The enforcement action demonstrates heightened scrutiny of providers, aggressive asset forfeiture, and a focus on cases involvin
United StatesCriminal Law
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

Emerging Enforcement Trends In Digital Health Data Privacy: Lessons From Washington’s My Health My Data, FTC vs. Hims & Hers And UCHealth Enforcement Actions

Federal and state regulators are intensifying scrutiny of healthcare and digital health companies over tracking technologies that share sensitive patient data with advertising platforms. Recent enforcement actions against major telehealth providers and healthcare systems reveal how common marketing practices can trigger significant legal liability under privacy laws, even for organizations not covered by HIPAA.
United StatesPrivacy
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

SEC Publishes The Long-Awaited Regulation Crypto Assets Proposed Rules

The SEC has proposed Regulation Crypto Assets, its most comprehensive digital asset framework to date, establishing exemptions for startups and fundraising while introducing an Investment Contract Safe Harbor that could formally determine when crypto assets are no longer subject to securities laws. As regulators shift from enforcement-focused approaches to clearer rulemaking, agencies continue targeting fraud and misconduct, signaling that compliance remains critical even as the regulatory landscape evolves
United StatesFinance and Banking
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP