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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 June 2, 2026, the Office of the U.S. Trade Representative (USTR) issued its determination under Section 301 of the Trade Act of 1974 that certain acts, policies, and practices of 60 economies related to the failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor are unreasonable and burden or restrict U.S. commerce.&nbsp; While acknowledging that some trading partners &ldquo;have taken initial steps to prevent the importation of forced labor goods, including through USMCA and commitments in Agreements on Reciprocal Trade,&rdquo; Ambassador Jamieson Greer stated that each trading partner &ldquo;must do more to ensure that trade does not perversely encourage and entrench forced labor globally.&rdquo;&nbsp;
These Section 301 investigations were initiated on March 12, 2026.&nbsp; See Thompson Hine Update of <a href="https://www.thompsonhinesmartrade.com/2026/03/ustr-launches-section-301-investigations-into-forced-labor-practices/">March 17, 2026</a>, for additional background information.&nbsp; The USTR has prepared a <a href="https://ustr.gov/sites/default/files/files/Press/Releases/2026/USTR%20Report%20Sec%20301%20FL%20301%206-2-26%20FINAL%20for%20upload.pdf">report</a>,&nbsp;Acts, Policies, and Practices of Various Economies Related to the Failure to Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced with Forced Labor, that sets forth the findings in each investigation.&nbsp; The report notes that 54 economies have failed to impose a legal prohibition on the importation of goods produced wholly or in part with forced labor and to effectively enforce such a prohibition; and, that six economies have failed to effectively enforce a forced labor import prohibition. The USTR has determined that the failure of each of the investigated economies to impose and effectively enforce a forced labor import prohibition is unreasonable because it: (1) undermines the universal aim of eliminating forced labor; (2) permits firms that avail themselves of forced labor to produce goods at a lower cost and thereby distort market conditions for firms that do not use forced labor; (3) undermines the profitability of firms that do not use forced labor; and (4) contributes to the circumvention of existing forced labor import prohibitions.
In issuing its <a href="https://ustr.gov/sites/default/files/files/Press/Releases/2026/FRN%20-%20Section%20301%20Forced%20Labor%20Import%20Ban%20Actionabilty%20and%20Proposed%20Action%206-2-26%20FINAL.pdf">Notice of Determination</a>, the USTR is proposing that appropriate action would include applying tariffs as follows:&nbsp; (i) For economies that impose a forced labor import prohibition; have taken on commitments related to forced labor import prohibitions through an Agreement on Reciprocal Trade; or have imposed a partial regime with the effect of preventing the importation of certain forced labor goods, a proposed additional duty rate of 10%; (ii) For all other economies, a proposed duty rate of &nbsp;12.5%.&nbsp; Annex A to the Notice sets forth proposed exemptions for certain goods, including all articles and parts currently subject to section 232 tariffs and raw materials that if subject to the proposed additional tariffs could lead to the unavailability of domestic supply. &nbsp;The proposed exempt Harmonized Tariff Schedule of the United States (HTS) list in Annex A also includes products that could cause economy-wide disruptions if subject to the proposed additional tariffs and certain products that cannot be grown or produced in sufficient quantities in the United States or obtained from other sources. The proposed exemptions include informational materials (e.g., books), donations, and accompanied baggage. Finally, the proposed exemptions include articles for which additional tariffs may not contribute substantially to the elimination of the investigated acts, policies, and practices described in the Notice of Determination.
Next Steps
The USTR is accepting public comments on the proposed actions and will hold a public hearing in July.
<ul class="wp-block-list">
<li>Interested persons should submit requests to appear at the public hearing, along with a summary of the testimony, by June 22, 2026.&nbsp;</li>
<li>Public comments on the proposed actions are due no later than July 6, 2026.&nbsp;</li>
<li>USTR will hold a public hearing on the proposed actions on July 7, 2026.</li>
</ul>

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

Partner

Samir D. Varma

David M. Schwartz

Francesca M.S. Guerrero

International Trade

USTR Proposes Tariffs of 10% to 12.5% in 60 Section 301 Forced Labor Investigations