On June 2, 2026, the Office of the United States Trade Representative (USTR) announced the findings of its trade investigation into 60 economies for failing to prohibit and enforce restrictions on the importation of goods produced with forced labor. USTR Ambassador Jamieson Greer proposed tariffs of 10% or 12.5% depending on the findings for each country.
Background
On February 20, 2026, the same day the United States Supreme Court held the administration’s tariffs imposed under the International Emergency Economic Powers Act of 1977 (IEEPA) unconstitutional, President Trump directed the Office of the USTR to initiate investigations in certain trade practices pursuant to section 301 of the Trade Act of 1974 (Trade Act).
On March 12, 2026, the USTR announced investigations into 60 economies (59 countries and the European Union) for failing to impose and/or enforce laws prohibiting the importation of goods manufactured with forced labor.
The USTR noted that, although most trading partners prohibit forced labor practices as a matter of law, “[I]n the absence of forced labor import prohibition that is effectively enforced, firms can continue to source, use, and profit from imported products produced with forced labor, even if the forced labor is prohibited domestically.”
On April 28 and 29, the USTR held public hearings on the investigation.
June 2 Announcement of Findings
On June 2, the USTR announced its findings that all 60 economies failed to either establish policies prohibiting the importation of goods produced with forced labor or to enforce such prohibitions. The USTR asserts these failures “burdens or restricts U.S. commerce and are thus actionable under section 301(b) of the Trade Act.” The USTR published a full report that documents its findings.
Ambassador Greer noted that the failure to establish these policies places Americans at a disadvantage.
“The failure of our most important trading partners to address the importation of goods made with forced labor is unacceptable. This creates a dynamic where American workers are forced to compete globally on an unlevel playing field,” Greer said. “We will no longer tolerate this disparity. Some trading partners have taken initial steps to prevent the importation of forced labor goods, including through USCMA and commitments in Agreements of Reciprocal Trade. However, each of our trading partners must do more to ensure that trade does not perversely encourage and entrench forced labor globally.”
The USTR’s proposed response to the findings is the imposition of tariffs as follows:
- 10% on imports of certain goods for those economies that have partial preventive regime and
- 5% for all other economies included in the investigation
The USTR has solicited comments through July 6, 2026, and will hold hearings on July 7, 2026.
Other News on Section 301 Trade Investigations
On May 29 the USTR opened a section 301 investigation of Vietnam to determine whether Vietnam’s “persistent failure to resolve long-standing concerns about intellectual property * * * protection and enforcement is unreasonable or discriminatory and burden or restricts U.S. commerce.”
On June 1 the USTR determined that certain of Brazil’s “acts, policies, and practices related to digital trade and electronic payment services; unfair, preferential tariffs; anti-corruption enforcement; intellectual property protection; ethanol market access; and illegal deforestation are unreasonable and burden or restricts U.S. commerce.” The proposed action in response at this time does not include the imposition of tariffs.
Your Guide Forward
Cherry Bekaert has a cross-functional team of professionals to help advise and support our clients with the downstream effects of tariffs and tariff refunds on tax, accounting, audit and financial reporting functions.
If you have questions about preserving your rights or about any other legal or trade implications that may exist, we recommend reaching out to appropriate legal counsel.
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