On July 23, 2026, United States Trade Representative (USTR) Jamieson Greer announced final action under Section 301 of the Trade Act of 1974, imposing new tariffs on goods from 60 countries found to have failed to impose or effectively enforce a prohibition on the importation of forced-labor goods. The tariffs took effect at 12:01 a.m. on July 24, timed to coincide with the expiration of the administration's temporary 10% Section 122 global tariff.

Two New Additional Baseline Rates

The final rule imposes two baseline rates layered on top of existing Most-Favored-Nation (MFN) and other duties.

• A 10% rate applies to goods from Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago and the United Kingdom – countries that impose a forced-labor import prohibition, have committed to one through an Agreement on Reciprocal Trade (ART) or maintain a partial regime preventing the importation of certain forced-labor goods.
• A 12.5% rate applies to all other investigated economies, including major trading partners such as China.

A Net-of-MFN Approach

For the European Union, Taiwan, Japan, South Korea and Switzerland, the USTR applies a net-of-MFN approach: the Section 301 duty is set so that the combined MFN and Section 301 rate reaches 10% for EU and Taiwan or 12.5% for Japan, South Korea and Switzerland. Collectively, the action covers roughly 99.4% of total U.S. imports.

Scope and Limits of Application

1. Any country not part of the Section 301 investigation will not have an additional Section 301 duty applied and will not be subject to Section 122 tariffs after they expire.
2. The new duties generally do not "stack" with Section 232 tariffs, properly claimed Chapter 98 treatment or USMCA-qualifying goods from Canada and Mexico.
3. Importers should not assume every product from a covered country is subject to the new duty. USTR carried forward nearly all the exemptions previously proposed and added 471 new exempted products. General exemptions applicable across all 60 countries also cover informational materials, accompanied baggage and goods already subject to Section 232 tariffs, among others.

To help guide implementation of the new tariffs, U.S. Customs and Border Protection has assigned each covered economy a specific, new Chapter 99 HTSUS heading (9903.05.20 through 9903.05.84) tied to its applicable duty rate, along with corresponding exemption headings in the 9903.05.85–9903.05.92. Importers, brokers and filers should also note the prescribed reporting sequence on entry summaries: Chapter 98 provisions first, followed by Chapter 99 numbers for Section 301, then Section 122, then Section 232, then Section 201 duties and quotas, in that order. Goods that were loaded onto a vessel and in transit before the July 24 effective date remain exempt if entered for consumption before 12:01 a.m. on July 28.

What’s Coming and How to Prepare

Importers with supply chains touching Bangladesh, Cambodia, Indonesia or Malaysia should also watch for a forthcoming tariff-rate quota (TRQ) mechanism for textile and apparel goods. The USTR intends to establish, when feasible, three-year TRQs calibrated to each economy's importation of U.S. cotton and textile inputs, allowing a defined volume of qualifying textile and apparel goods to enter duty-free. Until those TRQs are formally established through a separate Federal Register notice, the standard 10% Section 301 rate continues to apply to covered textile and apparel imports from those four countries.

Finally, importers should note that applying Section 301 to 60 countries covering nearly all U.S. imports in a single action is an unprecedented use of the statute that could draw major questions doctrine challenges like those raised against the administration's earlier IEEPA tariffs, which the Supreme Court struck down in February. Given this uncertainty, importers should track compliance deadlines and, perhaps more importantly, the amount of Section 301 tariffs they pay, to aid in recovery in the event the tariffs overturned and refunds are issued because the legal durability of this action is far from settled.

Miles & Stockbridge’s international trade lawyers will continue monitoring the implementation of the new tariffs and are available to answer questions about how the tariffs could affect your business.

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