Section 301 forced labor duties on goods from 60 economies: what the Importer of Record pays and declares

Since 12:01 a.m. eastern time on July 24, 2026, goods from 60 economies have carried an additional Section 301 duty of 10 or 12.5 percent, assessed on top of the normal column 1 rate and, with listed exceptions, on top of other Chapter 99 duties. The Office of the United States Trade Representative (USTR) imposed it at the close of 60 investigations into whether each economy prohibits the import of goods made with forced labor. Like every duty collected at entry, it is owed by the Importer of Record (IOR), and the Chapter 99 heading that triggers it is declared in the IOR’s name.

This post sets out what the action is and under what authority, which economies carry which rate, the exceptions written into the tariff schedule, how CBP has filers report it, and what the IOR documents. It also notes what the action does not do: the separate prohibition on importing goods made with forced labor under 19 U.S.C. §1307 is unchanged.

What USTR did and under what authority

USTR initiated the 60 investigations on March 12, 2026, under Section 302(b)(1) of the Trade Act of 1974, 19 U.S.C. §2412(b)(1) (91 FR 12884). On June 2, 2026, it determined that 54 economies had failed to impose and enforce a prohibition on importing goods produced with forced labor, and that six more, Canada, Ecuador, the European Union, Indonesia, Mexico, and Pakistan, had a prohibition but failed to enforce it (91 FR 34272). Hearings followed on July 7 to 9.

A presidential memorandum of July 23, 2026 directed the action (91 FR 47717). USTR’s notice of action followed at 91 FR 47318, published July 28, 2026, under Section 301(b) and Section 304(a) of the Trade Act, 19 U.S.C. §2411(b) and §2414(a), with the modification authority of Section 307, 19 U.S.C. §2417. The duties apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on July 24, 2026, with an in-transit exception for goods loaded before that time and entered before 12:01 a.m. on July 28.

The rates by economy

The action creates a new U.S. note 52 in subchapter III of chapter 99 of the Harmonized Tariff Schedule, with one heading per economy (9903.05.20 through 9903.05.84) and a block of exemption headings (9903.05.85 through 9903.06.21). Three rate groups apply.

10 percent. Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, and the United Kingdom. The notice ties this rate to economies that impose a forced labor import prohibition, have committed to one through an Agreement on Reciprocal Trade, or operate a partial regime.

Net of the MFN rate. For products of the European Union and Taiwan, the Section 301 duty is set so that the column 1 rate and the Section 301 rate add to 10 percent; where the column 1 rate is already 10 percent or more, the Section 301 rate is zero. The same mechanism applies to Japan, South Korea, and Switzerland at 12.5 percent. Where the column 1 rate is specific or compound rather than a percentage, note 52(k) converts it to an ad valorem equivalent by dividing the duty payable by the customs value.

12.5 percent. Goods of every other investigated economy. CBP’s guidance lists them heading by heading; the group includes Australia, Brazil, China, Hong Kong, Israel, the Philippines, Saudi Arabia, Singapore, Thailand, Türkiye, the United Arab Emirates, and Vietnam, among others.

The rate follows the country of origin of each line on the entry, so one shipment with goods of two origins carries two headings and two rates.

The exceptions written into note 52

The exemption headings are the part of the action that most often changes what a given entry owes:

• Goods in transit in late July 2026 (9903.05.85), products listed in Annex I of the notice (9903.05.86), and a short list of named articles (9903.05.87)
• Civil aircraft and parts (9903.05.88) and listed pharmaceutical applications (9903.05.89)
• Articles already subject to Section 232 duties, listed by their Section 232 heading numbers: articles of aluminum, steel, and copper and their derivative articles, passenger vehicles and light trucks, medium and heavy trucks and their parts, wood products, and semiconductors (9903.05.90, note 52(f))
• Donations and informational materials (9903.05.91 and 9903.05.92)
• Products of Canada (9903.05.93) and Mexico (9903.05.94) entered free of duty under the United States-Mexico-Canada Agreement
• Textiles and apparel of six CAFTA-DR countries (9903.05.95), and economy-specific annexes for the United Kingdom, the European Union, Switzerland, Malaysia, Cambodia, Jordan, and others (9903.05.96 through 9903.06.21)

Goods entered under chapter 98 are outside the action except for 9802.00.40, 9802.00.50, and 9802.00.60 (duty on the value of repairs or alterations) and 9802.00.80 (duty on the value assembled abroad). Covered goods admitted to a foreign trade zone on or after July 24, 2026 may be admitted only as privileged foreign status. The duties are in addition to the column 1 rate and to other duties, fees, and charges, including other Chapter 99 duties, except as the exemption subdivisions provide. Tariff rate quotas for textiles of Bangladesh, Cambodia, Indonesia, and Malaysia are to be set by a later notice; as of October 19, 2026, none has been published.

How CBP has filers report it

CBP’s guidance is CSMS #69326983 of July 23, 2026, with an attached HTS list. It restates each economy’s heading and rate and the exemption headings, and sets the order of reporting on the entry summary line: any chapter 98 provision first, then the Chapter 99 additional duty headings in a fixed order (Section 301, Section 122, Section 232, Section 201), and last the chapter 1 to 97 classification carrying the entered value. CBP’s trade remedies page lists this CSMS and 91 FR 47318 as the operative documents.

What the action does not change

The notices and the CSMS message address rates and reporting. None of them amends 19 U.S.C. §1307, which prohibits the import of goods produced wholly or in part with forced labor, or the Uyghur Forced Labor Prevention Act; the June 5 notice mentions §1307 only as background. That prohibition operates on admissibility, not on duty rates. The Section 301 duty is collected on goods that are admissible.

As of October 19, 2026, USTR has published no modification to the action: no rate change, no added exclusion beyond the annexes in the original notice, and no tariff rate quota notice.

What the IOR documents

The duty turns on facts that only the IOR’s records answer:

• The country of origin of each line, because the heading and the rate follow origin
• Whether the article is classified in a Section 232 heading listed in note 52(f), which takes it out of the action
• For goods of Canada or Mexico, whether the entry is made free of duty under USMCA, which is the condition for headings 9903.05.93 and 9903.05.94
• For goods of the European Union, Taiwan, Japan, South Korea, or Switzerland, the column 1 rate on each line, because the Section 301 rate is the difference up to 10 or 12.5 percent
• Any chapter 98 claim, any foreign trade zone status, and, for July 2026 entries, the vessel loading date behind an in-transit claim
• The Chapter 99 headings declared and their order on the line, as CSMS #69326983 sets out

Each of those is a declaration made in the IOR’s name on the entry summary. The Importer of Record page explains what the role requires, and the 2026 requirements summary carries the current enforcement position. Tell us what you import and how your entries are filed today, and we’ll show you where you stand: see if you qualify or write to ship@iorusa.com.

Sources

• USTR, Notice of Actions in Section 301 Investigations of Acts, Policies, and Practices of Various Economies Related to the Failure of Each Economy To Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced With Forced Labor, 91 FR 47318, July 28, 2026
• Presidential memorandum, Actions by the United States in the Investigations Under Section 301 of the Trade Act of 1974, 91 FR 47717, July 28, 2026
• USTR, determination and proposed action, 91 FR 34272, June 5, 2026
• USTR, initiation of investigations, 91 FR 12884, March 17, 2026
• CBP, CSMS #69326983, Guidance: Section 301 Forced Labor Import Duties, July 23, 2026
• USTR press release, USTR Takes Action in Forced Labor Section 301 Investigations, July 23, 2026
• USTR press release, USTR Initiates 60 Section 301 Investigations Relating to Failures to Take Action on Forced Labor, March 12, 2026
• 19 U.S.C. §1307, Convict-made goods; importation prohibited