On July 24, 2026, new Section 301 duties targeting imports from 60 economies took effect as part of a U.S. Trade Representative (USTR) action addressing forced labor concerns in global supply chains.
The additional duties apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on July 24, 2026.
The action imposes additional duties of 10% or 12.5%, depending on the country of origin and applicable Chapter 99 HTSUS provision.
Key considerations for importers
- Review whether products are sourced from one of the 60 economies covered by the action
- Confirm the applicable Chapter 99 HTSUS classification and corresponding additional duty rate
- Determine whether any country-specific exclusions or product exemptions apply
- Review entry timing to ensure compliance with the July 24, 2026 implementation date
- Work with customs brokers and suppliers to identify potentially affected imports and evaluate duty exposure
Duty structure
The Section 301 Forced Labor action establishes additional duties of either 10% or 12.5% on imports from designated economies.
Certain countries and customs territories, including the European Union, Japan, South Korea, Switzerland, and Taiwan, are subject to special tariff provisions in which the Section 301 duty is applied as a combined duty rate rather than as an additional ad valorem duty.
The new duties are administered through HTSUS Chapter 99 provisions 9903.05.20 through 9903.05.84 and apply in addition to any normal trade relations (MFN) duty rates unless an exemption or exclusion applies.
Exclusions and special provisions
The action includes several general exemptions applicable to all covered economies.
Excluded products include:
- Certain in-transit goods loaded and exported prior to the effective date
- Specified products identified in U.S. Note 52
- Civil aircraft, aircraft engines, parts, components, subassemblies, and flight simulators
- Articles intended for pharmaceutical applications
- Certain aluminum, steel, copper, derivative metal products, passenger vehicles, vehicle parts, medium- and heavy-duty vehicles, wood products, and semiconductor articles
- Humanitarian donations, including food, clothing, and medicine intended to relieve human suffering
- Informational materials, including publications, films, photographs, audio recordings, software media, artworks, and news wire feeds
Numerous economy-specific exclusions are also available for qualifying imports from Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, European Union member states, Guatemala, Indonesia, Jordan, Malaysia, Mexico, Switzerland, Taiwan, the United Kingdom, and certain CAFTA-DR countries.
Additional exemptions apply to qualifying USMCA and CAFTA-DR imports, including certain textiles and apparel articles entered duty free under those agreements.
Importers should carefully review the applicable Chapter 99 provisions and U.S. Note 52 exclusions to determine whether their products qualify for relief from the additional duties.
Chapter 98 provisions
The additional duties imposed by headings 9903.05.20 through 9903.05.84 do not apply to goods properly entered under Chapter 98 provisions of the HTSUS, except for goods entered under subheadings 9802.00.40, 9802.00.50, 9802.00.60, and 9802.00.80.
For goods entered under subheadings 9802.00.40, 9802.00.50, and 9802.00.60, the additional duties apply only to the value of repairs, alterations, or processing performed abroad.
For goods entered under subheading 9802.00.80, the additional duties apply only to the foreign value added to the assembled article.
Products remain subject to any applicable antidumping duties, countervailing duties, taxes, fees, exactions, and other charges.
Foreign Trade Zone (FTZ) provisions
Any product subject to the Section 301 Forced Labor duties that is admitted into a U.S. Foreign Trade Zone, unless eligible for Domestic Status under 19 C.F.R. §146.43, may only be admitted in Privileged Foreign Status under 19 C.F.R. §146.41 effective on the date the additional duty is imposed.
Importers utilizing FTZ programs should review inventory and admission procedures to ensure compliance with the new requirements.
Importer action items
- Review sourcing by country of origin
- Identify affected Chapter 99 classifications
- Determine whether any general exemptions apply
- Evaluate whether economy-specific exclusions are available
- Review Chapter 98 eligibility
- Assess FTZ admission procedures
- Coordinate with customs brokers, suppliers, and trade compliance teams prior to filing entries
Additional details regarding the new Section 301 Forced Labor duties, including applicable HTSUS provisions and exclusion criteria, can be found in CSMS #69326983, issued on July 23, 2026.
General questions may be directed to your Livingston account representative.