This week, the Office of the U.S. Trade Representative (USTR) published multiple Federal Register notices announcing the initiation of Section 301 investigations into trade practices in Vietnam and forced labor practices of 60 U.S. trading partners. Additionally, USTR issued a final determination under Section 301 regarding Brazil’s trade practices.
Each one of these actions carries tight deadlines for the trade community to review and participate in the public comment process.
Vietnam – Proposed Action Pending
The Section 301 investigation on Vietnam, initiated on May 29, 2026, focuses on intellectual property (IP) protection and enforcement policies, following Vietnam’s designation as a “Priority Foreign Country” in the April 30, 2026, Special 301 Report. USTR is soliciting comments on the nature and extent of Vietnam’s IP-related practices, their impact on U.S. commerce, and potential U.S. responses.
Public comments are due by July 2, 2026.
Federal Register notice - here
Forced Labor – Proposed 10% or 12.5% Tariff
On June 2, 2026, USTR issued its findings from the Report in Section 301 Investigations covering 60 countries related to the importation of goods produced with forced labor. USTR determined that all 60 countries have failed to effectively address the issue.
The list includes: Argentina, Australia, Brazil, Canada, Chile, China, the EU, India, Japan, Mexico, Norway, Singapore, South Korea, Switzerland, Taiwan, the United Kingdom and Vietnam.
In a Federal Register notice, USTR proposed two categories of remedies:
Certain exemptions would apply, as outlined in Annex A to the Federal Register notice. These include goods subject to Section 232 measures, specified raw materials, products not produced in sufficient quantities in the U.S., USMCA-compliant goods of Canada or Mexico, qualifying textile and apparel articles under CAFTA-DR, and other specified categories.
Public comments are due by July 6, 2026, with the hearing to follow on July 7, 2026.
Brazil – Proposed 25% Tariff
USTR initiated its investigation on Brazil on July 15, 2025. The review covered a broad range policies and practices with Brazil’s trade environment, including digital trade and electronic payment, preferential tariff, anti-corruption enforcement, intellectual property protection, ethanol market access, and illegal deforestation. The USTR has determined that Brazil’s policies and practices are unreasonable, and burden or restrict U.S. commerce.
The USTR has proposed significant trade remedies, including:
Public comments are due by July 1, 2026, with a public hearing to follow on July 6, 2026. A final determination is expected in July.
Federal Register notice - here
Shippers should closely monitor these developments and assess exposure, particularly where Vietnam, Brazil, or any of the 60 countries identified in the forced labor investigation are integral to their supply chain sourcing.
For all investigations, public comments and requests to appear at the public hearing can be filed here.
If you have any questions, please contact your C. H. Robison representative.