USTR Section 301 Forced Labor: 60 Countries Explained

On March 12, 2026, the US Trade Representative initiated 60 simultaneous Section 301(b) investigations into trading partners that together account for 99% of US imports. The stated trigger is forced labor enforcement, but the broader context is the Supreme Court's February ruling that struck down IEEPA tariffs. Public hearings begin April 28 at the US International Trade Commission. This guide explains what the investigations cover, why the list is so broad, and what exporters should be doing before July 24 — when temporary Section 122 tariffs expire and new Section 301 remedies are likely to land.

What did USTR just initiate against 60 countries?

On March 12, 2026, USTR launched investigations under Section 301(b) of the Trade Act of 1974 into 60 economies that together accounted for 99% of US imports in 2024. The stated focus is whether each country has failed to impose and effectively enforce a ban on the importation of goods produced with forced labor, and whether that failure burdens or restricts US commerce in a way that meets the Section 301 standard.

USTR Ambassador Jamieson Greer characterized the issue as a failure by governments to impose and enforce existing measures against goods produced with forced labor. The list, published in Annex A of Federal Register Doc 2026-05151, includes China, the European Union, the United Kingdom, Canada, Mexico, Japan, South Korea, India, Australia, Brazil, and dozens of others.

A separate Section 301 investigation, launched the day before on March 11, targets 16 economies for excess capacity and overproduction in specific manufacturing sectors. That list — China, EU, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, South Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India — overlaps entirely with the 60-country forced labor list.

Why is the list so broad, including countries with strong labor laws?

The breadth of the list is the point. The investigations are USTR's legal mechanism to reach trading partners that account for nearly all US imports, not just countries with documented forced labor problems. According to law firm Mayer Brown, the list pulls in many developed economies — Australia, the EU, Japan, Norway, South Korea, Switzerland, the UK, and others — that have no significant US-side record of forced labor concerns.

Several of those economies have already adopted forced labor import bans. The European Union's Forced Labour Regulation, adopted December 2024, bans the sale, import, and export of goods made using forced labor on the EU market. Canada has prohibited the importation of forced labor goods since July 2020 under USMCA. Mexico has implemented similar measures. Despite these existing prohibitions, USTR's notice asserts that none of the 60 economies has, in its view, both adopted a forced labor import prohibition and effectively enforced it to date.

That phrasing is doing the work. By framing the question as one of effective enforcement rather than just legal prohibition, USTR can include countries that have laws on the books but, in USTR's view, have not enforced them to a sufficient standard.

How does this connect to the IEEPA tariff ruling?

The Supreme Court ruled on February 24, 2026, that the International Emergency Economic Powers Act (IEEPA) does not give the president authority to impose tariffs. The ruling forced the administration to rescind the so-called "Liberation Day" tariffs originally imposed in April 2025.

The response was a two-track replacement strategy:

• Section 122 tariffs: A temporary 10% global tariff imposed January 24, 2026 under Section 122 of the Trade Act of 1974. Section 122 tariffs can be implemented quickly but are capped at 15% and 150 days. They expire July 24, 2026.

• Section 301 investigations: Longer-term tariffs that require an investigation and a finding, but rest on stronger legal precedent.

The first-term Section 301 tariffs on Chinese imports, covering roughly $370 billion in goods, were also imposed under this statute and remain in place today. According to law firm Davis Wright Tremaine, Treasury Secretary Scott Bessent has stated his expectation that the tariff rates will be back to their previous level once the Section 122 tariffs expire.

In practical terms: IEEPA was the fast vehicle. Section 301 is the durable one.

What is the timeline that exporters need to track?

The schedule is compressed. Ambassador Greer has stated the investigations will follow an expedited timeline so that proposed remedies are ready before Section 122 expires.

The key dates are:

• March 12, 2026: USTR initiated the 60-country forced labor investigation.

• April 15, 2026: Deadline for written comments and requests to appear at hearings (closed).

• April 28, 2026: Public hearings begin at the US International Trade Commission, 500 E Street SW, Washington DC, at 10:00 AM.

• May 1, 2026: Hearings may continue through this date if necessary.

• July 24, 2026: Section 122 tariffs expire. USTR's likely target for Section 301 remedies to be announced or implemented.

Section 301 investigations normally must conclude within 12 months of initiation. In this case, USTR is targeting roughly 4.5 months from initiation to remedy.

Which sectors are most exposed?

USTR's notice and supporting materials emphasize sectors that already feature in forced labor and supply chain debates. According to law firm Arnall Golden Gregory, these include textiles and apparel, footwear and consumer goods, agriculture and seafood, electronics, solar products and batteries, and auto parts and critical mineral inputs.

The US Department of Labor's 2024 List of Goods Produced by Child Labor or Forced Labor (TVPRA List) identifies 134 products produced with forced labor in particular countries. The list also flags 34 downstream goods that contain forced labor inputs. Examples cited in USTR's Federal Register notice include cotton used in garments and textiles, critical minerals used in solar products and auto parts, fish used in fish oil and fish meal, and palm fruit used in cooking oils and biofuels.

Sectors not traditionally associated with forced labor are also exposed if their inputs trace back to flagged sources. A company in Germany that exports auto parts to the US may have no labor concerns of its own, but if its critical mineral inputs trace to a region under TVPRA scrutiny, that sourcing footprint becomes a Section 301 risk factor.

How is Section 301 different from UFLPA and existing forced labor bans?

The Section 301 investigations do not change existing US law. According to law firm White & Case, the Tariff Act's Section 307 (19 U.S.C. 1307) prohibition on forced labor imports, the Uyghur Forced Labor Prevention Act (UFLPA), and existing CBP Withhold Release Orders all remain in force.

The difference is in the remedy. Section 307 lets CBP detain individual shipments suspected of containing forced labor. UFLPA creates a rebuttable presumption against goods from the Xinjiang Uyghur Autonomous Region. These tools target shipments and products.

A Section 301 finding, by contrast, can result in country-wide tariffs on a much broader range of goods. A finding against Vietnam or Cambodia, for example, could mean additional ad valorem duties on all imports from those countries — not only imports suspected of containing forced labor inputs.

That is why this is described as a structural shift. According to law firm Arnall Golden Gregory, USTR is for the first time deploying Section 301(b) as a country-wide instrument aimed at how trading partners enforce forced labor import controls.

What should exporters do before July 24?

Three actions are still possible after the comment deadline.

Map your country exposure. Identify every country in your supply chain — first-tier suppliers, sub-suppliers, and the origin of critical inputs — that appears on the 60-country list. The full Annex A is published in Federal Register Doc 2026-05151. Any sourcing footprint in those countries is a potential Section 301 risk factor.

Track the hearing record. Public hearings beginning April 28 will produce a public record that may signal which countries USTR is most concerned about. Post-hearing rebuttal comments are accepted for 7 days after the last hearing day. The USTR comment portal at comments.ustr.gov hosts the dockets — docket number USTR-2026-0133 for the forced labor investigation.

Prepare for parallel enforcement. A Section 301 finding does not eliminate existing forced labor enforcement; it overlays new tariffs on top of existing detentions. Companies that already have UFLPA exposure should expect detention risk to continue while new tariff risk is added.

The comment window closed April 15. The hearing window is now. The remedy window is July. Exporters who wait for tariff rates to be announced before assessing exposure will lose months they cannot recover.