Trade Advisory America First Update

Section 301 Investigations Expanded to 60 Economies

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On March 12, 2026, the Office of the United States Trade Representative (USTR) initiated Section 301 investigations into 60 economies to evaluate whether foreign governments have failed to effectively prohibit the importation of goods produced with forced labor. The investigations cover nearly all major U.S. trading partners, representing over 99% of total U.S. imports, and mark a significant expansion of U.S. trade enforcement activity.

What we know

The investigations are being conducted under Section 301(b) of the Trade Act of 1974, which authorizes the United States to impose tariffs or other trade remedies without additional congressional approval if unfair or discriminatory trade practices are confirmed. This development reflects a broader policy shift toward Section 301 as a durable enforcement tool, particularly following recent court decisions that limited the use of tariffs imposed under other statutory authorities.

USTR has initiated two distinct Section 301 investigations. Notably, the forced labor investigations announced on March 12, 2026, cover 60 economies, while a separate Section 301 investigation launched one day earlier focuses on structural excess manufacturing capacity across 16 economies. Several jurisdictions—including China, the European Union, India, Japan, Mexico, and Vietnam—are subject to both investigations, increasing the likelihood of future trade action affecting those markets.

At this stage, no tariffs, duty increases, or product-specific measures have been announced, and there is no immediate impact on current duty rates or U.S. Customs procedures. However, the initiation of these investigations establishes a clear legal pathway for future tariffs or import restrictions, potentially on an accelerated timeline once USTR completes consultations, receives public comments, and conducts hearings.

What this means for importers

While near-term operational impacts are limited, these investigations materially increase policy and tariff risk for global supply chains. Companies with sourcing, manufacturing, or supplier exposure to the economies under review should anticipate heightened scrutiny of supply-chain practices and be prepared for potential trade remedies later in 2026.

USTR has indicated that this process will continue to evolve. Additional guidance, findings, and potential trade actions are expected as developments come to light, and further updates will be issued as the investigations progress.

If your organization could be impacted by these potential tariff measures, our Tariff Response Unit is ready to support you. Get immediate guidance on tariff modeling, compliance preparation, and fast-moving regulatory developments.