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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On March 12, 2026, the U.S. Trade Representative (USTR) announced that it was launching Section 301 investigations into 60 trade partners to determine whether they have been engaged in forced labor practices. The investigations, to be conducted pursuant to Section 301of the Trade Act of 1974, include China, the European Union, India, and Mexico.&nbsp;A full list of the trade partners involved is provided in Annex A of the forthcoming <a href="https://ustr.gov/sites/default/files/files/Press/Releases/2026/FRN%20-%20Forced%20Labor%20Import%20Ban%20301%20-%20FINAL.pdf" target="_blank" rel="noreferrer noopener">Federal Register notice</a>.&nbsp;
While U.S. law prohibits the importation of goods mined, produced, or manufactured in whole or in part with forced labor and &ldquo;it is universally recognized under international law that forced labor is a practice that should not be tolerated&rdquo;,&nbsp;the Federal Register notice states that the use of forced labor persists despite this consensus and the &ldquo;failure to prevent trade in products produced with forced labor may negatively affect U.S. commerce.&rdquo;
Under Section 301, actionable matters include acts, policies, and practices of a foreign country that are unreasonable or discriminatory and burden or restrict U.S. commerce.&nbsp;A possible response is the imposition of tariffs on trade partners that have been found to engage in unfair trade practices. President Donald Trump relied on this legal authority during his first term to levy duties on imported Chinese goods, and just last week announced separate Section 301 investigations into the excessive industrial practices of 16 trade partners, including China, Australia, Indonesia, Japan, Malaysia, Singapore, South Korea, Switzerland, and Thailand. See Thompson Hine Update of <a href="https://www.thompsonhinesmartrade.com/2026/03/ustr-initiates-section-301-investigations-into-the-acts-policies-practices-of-certain-economies-relating-to-structural-excess-capacity-and-production-in-manufacturing-sector/">March 12, 2026</a>.&nbsp;These investigations follow the U.S. Supreme Court&rsquo;s February 20, 2026 ruling invalidating tariffs President Trump implemented under the authority of the International Emergency Economic Powers Act (IEEPA) in 2025. See Thompson Hine Update of <a href="https://www.thompsonhinesmartrade.com/2026/02/u-s-supreme-court-invalidates-ieepa-as-a-lawful-authority-to-impose-tariffs/">February 20, 2026</a>.
<h2 class="wp-block-heading">Investigation Timeline</h2>
Upon initiation of an investigation, the USTR must first seek consultations with the countries or trade partners subject to the investigations. The USTR must also seek public comment and hold a hearing on the matter. The following dates have been scheduled:
<ul class="wp-block-list">
<li>March 12, 2026: The USTR opened the dockets for submission of written comments and requests to appear at the hearings.</li>
<li>April 15, 2026: Submissions are due on this date for written comments, hearing appearance requests, and summaries of testimony.</li>
<li>April 28, 2026: The Section 301 Committee will convene public hearings in the main hearing room of the U.S. International Trade Commission, 500 E Street SW, Washington, D.C., 20436, beginning at 10 a.m. EDT, continuing, as necessary, until May 1.</li>
<li>Seven calendar days after the last day of the public hearing will be the deadline for submission of any post-hearing rebuttal comments.</li>
</ul>
Interested parties should submit documents in response to this notice, including written comments, hearing appearance requests, summaries of testimony, and post-hearing rebuttal comments, through the online USTR portal:&nbsp;<a href="https://comments.ustr.gov/s/" target="_blank" rel="noreferrer noopener">https://comments.ustr.gov/s/</a>&nbsp;on Docket No. USTR-2026-0133 (request for public comments) and USTR-2026-0134 (request to appear at the hearing).
<h2 class="wp-block-heading">Request for Public Comments</h2>
Interested parties are invited to submit written comments on any issue covered by the investigation. The USTR particularly requests comments regarding:
<ul class="wp-block-list">
<li>Whether any trade partner subject to these investigations maintains or is in the process of establishing a forced labor import prohibition, and whether any such import prohibition is being effectively enforced.</li>
<li>The extent to which the failure of any trade partner to establish and effectively enforce a forced labor import prohibition is unreasonable, discriminates against U.S. goods, or constitutes a persistent pattern of conduct that permits any form of forced or compulsory labor.</li>
<li>The extent to which the failure of any trade partner to establish and effectively enforce a forced labor import prohibition has negatively affected U.S. commerce, such as through lost U.S. exports or economic output, lower prices for U.S. goods, or lower wages for U.S. workers.</li>
<li>What action, if any, should be taken to address these issues, including: (i) the level and scope, if any, of duties on products of any trade partner subject to these investigations, and (ii) the level and scope, if any, of import restrictions on products of any trade partner subject to these investigations.</li>
<li>The appropriate aggregate level of trade to be covered by any additional duties on products of any trade partner subject to these investigations.</li>
</ul>

USTR Launches Section 301 Investigations into Forced Labor Practices

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