On July 23, President Trump issued a memorandum directing the U.S. Trade Representative to impose tariffs on goods from 60 economies found to have failed to ban imports made with forced labor.
The tariffs took effect at 12:01 a.m. Eastern time on July 24, only hours after their announcement, coinciding precisely with the expiration of the temporary Section 122 surcharge.
The Section 122 surcharge had imposed a flat 10% temporary measure on most imports worldwide, but the new Section 301 duties arise from 60 separate country-specific investigations and will remain in effect until modified or terminated.
The final action materially differs from the June proposal, with five economies moving from the proposed 12.5% rate to 10% after adopting forced-labor import prohibitions or making qualifying trade commitments.
Honduras, India, Jordan, Sri Lanka, and Trinidad and Tobago are among those receiving the lower 10% rate, while five other economies received MFN-based tariff floors rather than flat additional duties.
The European Union and Taiwan now face a total MFN-plus-Section 301 rate of 10%, while Japan, South Korea and Switzerland face a 12.5% floor under the new framework.
USTR added 471 general product exclusions and 13 country-specific exclusion lists to the final action, expanding relief substantially beyond what the June proposal had contemplated.
Critically, a clean supply chain does not eliminate the tariff liability, as these duties are designed to pressure foreign governments into adopting and enforcing their own import bans on forced-labor goods.
Paying the duty or qualifying for an exclusion does not protect goods from detention or exclusion under 19 U.S.C. Section 1307, the Uyghur Forced Labor Prevention Act, or a Withhold Release Order.
USTR declined to create an exclusion-request process comparable to the China Section 301 application system, meaning further relief is more likely to come through bilateral negotiations or later USTR modification.
The textile mechanism for Bangladesh, Cambodia, Indonesia and Malaysia will establish three-year tariff-rate quotas allowing qualifying textile and apparel volumes to enter free of the new duty, though the 10% rate applies until a later Federal Register notice implements those quotas.
Importers face several immediate compliance priorities, including building a product-origin-entry matrix that captures country of origin, HTSUS classification, MFN rate and applicable Chapter 99 heading for each product.
Importers must also validate entry claims and broker instructions, confirm preferential trade agreement support such as USMCA and CAFTA-DR, and model cumulative duty exposure including Section 232 measures and antidumping and countervailing duties.
The in-transit exception is narrow, covering only goods loaded onto a vessel and in transit before 12:01 a.m. on July 24 that enter for consumption before 12:01 a.m. on July 28, with no comparable relief for air, truck or rail shipments.
Litigation is considered likely, though USTR included detailed severability provisions intended to preserve remaining country actions if a court invalidates any particular provision, meaning a successful legal challenge may not unwind the entire programme.