On July 23, 2026, the Office of the U.S. Trade Representative (USTR) announced a new Section 301 trade action addressing forced labor concerns. As of 12:01 a.m. EDT on July 24, 2026, imports from 60 designated countries and economies are subject to additional duties of 10% or 12.5%, unless specifically exempted.
The tariffs apply to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on July 24, 2026.
Key Takeaways
- Broad Scope: The new duties apply to most products classified in Chapters 1-97 of the HTSUS from the identified countries and economies.
- Tariff Rates: Imports will generally be subject to either a 10% or 12.5% additional ad valorem duty, depending on the country of origin.
- Major Trading Partners Affected: The action includes imports from countries such as Canada, Mexico, China, India, Vietnam, the European Union, the United Kingdom, Japan, South Korea, Taiwan, and Switzerland, among others.
- Limited Exemptions: USTR has established several product- and country-specific exclusions, as well as broad exemptions for certain categories of goods.
Important Exemptions
Several significant exemptions remain available, including:
- United States-Mexico-Canada Agreement (USMCA) qualified products from Canada and Mexico that enter duty-free under the agreement
- Dominican Republic-Central America Free Trade Agreement (CAFTA-DR) qualifying textile and apparel products from certain Central American countries
- Civil aircraft and aircraft parts
- Pharmaceutical-use products
- Informational materials such as books, publications, films, and media
- Certain products already subject to other tariff programs, including specified steel, aluminum, vehicle, wood, and semiconductor products
- Most goods properly entered under qualifying Chapter 98 provisions
In-Transit Relief
The Section 301 Forced Labor action includes an in-transit exemption that applies only to ocean freight shipments. Cargo arriving in the United States by other transportation modes, including air, truck, or rail, does not qualify for this exemption.
To qualify for the in-transit exemption, goods must meet both of the following conditions:
- The goods must have been loaded onto a vessel at the port of loading and in transit on the final mode of transit prior to entry into the U.S. before 12:01 a.m. Eastern time on July 24, 2026; and
- The goods must be entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. on July 28, 2026.
Importer Considerations
Importers should evaluate sourcing and duty impacts, verify eligibility for applicable exemptions, and work closely with customs brokers to ensure compliance with the new Chapter 99 reporting requirements now in effect. Importers are also encouraged to review the CBP guidance and HTSUS attachment to determine whether their products are affected and to identify the corresponding Chapter 99 tariff provisions.
Please reach out to your C.H. Robinson representative with any questions.
Resources
CSMS # 69326983 - GUIDANCE: Section 301 Forced Labor Import Duties
Forced Labor HTS LIST.pdf