The Office of the U.S. Trade Representative (USTR) has announced several significant Section 301 trade actions that may affect your supply chain. Here is a summary of the key developments.

On June 2, 2026, USTR announced a Section 301 determination that 60 countries are trading in goods made with forced labor. USTR has proposed additional duties on all products from the investigated economies at the following rates:

  • 10% — for countries that have a forced labor import prohibition in place, have committed to one through a trade agreement, or have imposed a partial regime preventing certain forced labor goods from entering the U.S.
  • 12.5% — for all other investigated economies

USTR has also proposed a textile mechanism that would allow a certain volume of apparel and textile imports from certain economies to enter the U.S. at a reduced Section 301 rate.

Key dates for this action:

  • June 22 — Deadline to request appearance at hearings and submit a testimony summary
  • July 6 — Written comments due
  • July 7 — USTR public hearings on proposed actions
BRAZIL: PROPOSED 25% SECTION 301 TARIFFS

Separately, USTR has proposed a 25% Section 301 tariff on certain imports from Brazil following an investigation into Brazil’s trade practices, including concerns related to digital trade, electronic payments, preferential tariffs, anti-corruption enforcement, intellectual property, ethanol market access, and illegal deforestation.

The proposed tariffs would not apply to products already subject to Section 232 duties and would exclude certain raw materials and goods for which adequate domestic or alternative supply is unavailable.

VIETNAM: NEW SECTION 301 INVESTIGATION INITIATED

On May 29, 2026, USTR initiated a Section 301 investigation into Vietnam’s intellectual property protection and enforcement practices, following Vietnam’s designation as a “Priority Foreign Country” in the 2026 Special 301 Report. No additional duties have been announced at this time, but the investigation could ultimately lead to tariff actions on products imported from Vietnam.

WHAT IMPORTERS SHOULD DO

Importers sourcing from any of the 60 investigated countries should assess their exposure to the proposed 10–12.5% duties and consider participating in the comment process before July 6. Importers with Brazil exposure should review their product classifications against the proposed 25% tariff and consider submitting comments by July 1. Importers sourcing from Vietnam should monitor developments closely as the investigation progresses.

We will continue to monitor all of these actions and provide updates as additional information becomes available.