Section 301 Forced Labor Tariffs Now in Effect: What Importers Need to Know After the Expiration of Section 122 Duties

Effective Date: July 24, 2026 

On July 23, 2026, U.S. Trade Representative (USTR) Ambassador Jamieson Greer announced final action under Section 301 of the Trade Act of 1974, imposing additional tariffs on imports from 60 economies for failing to impose or effectively enforce prohibitions on the importation of goods produced with forced labor. The new measures became effective on July 24, 2026. At the same time, the temporary tariffs imposed under Section 122 of the Trade Act of 1974 expired, creating a significant shift in the overall U.S. tariff landscape. 

Section 301 Forced Labor Tariffs 

The new Section 301 duties apply to 60 economies and are intended to address what USTR determined are unreasonable trade practices related to the importation of goods produced with forced labor. Following investigations, public hearings, consultations with foreign governments, and review of more than 2,100 public comments, USTR finalized additional duties of either 10% or 12.5%, depending on the economy's forced labor enforcement framework. 

10% additional duty for economies that maintain a forced labor import prohibition, have committed to implement one through an Agreement on Reciprocal Trade (ART), or maintain a partial regime restricting certain forced labor goods. 

12.5% additional duty for all other investigated economies. 

Key Exclusions and Exemptions 

The additional duties do not apply to goods already subject to Section 232 measures, certain vehicles and vehicle parts, aluminum, steel, copper, civil aircraft and parts, semiconductors, patented pharmaceuticals, certain energy products, fish products, potash, and critical minerals. 

Goods that were loaded onto a vessel and in transit before July 24, 2026, are excluded, provided they are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. Eastern Time on July 28, 2026.  

In addition, qualifying goods entered duty-free under the USMCA are exempt from these new Section 301 duties for both Canada (HTSUS 9903.05.93) and Mexico (HTSUS 9903.05.94). Certain country-specific exemptions also apply, including exemptions associated with qualifying CAFTA-DR countries. 

Expiration of Section 122 Tariffs 

Concurrent with the implementation of the new Section 301 measures, the temporary tariffs imposed under Section 122 of the Trade Act of 1974 are set to expire on July 24, 2026. As a result, importers should not assume that overall duty costs will increase by the full amount of the new Section 301 tariffs. The net impact will depend on the country of origin, product classification, eligibility for exclusions, and the applicability of other trade measures. 

Recommended Importer Actions 

• Review sourcing exposure across the 60 affected economies. 
• Determine whether products qualify for any of the new exclusions. 
• Confirm USMCA or CAFTA-DR eligibility where applicable. 
• Recalculate landed costs considering both the new Section 301 duties and the expiration of Section 122 tariffs. 
• Evaluate cumulative exposure from Section 232 duties, existing Section 301 duties, IEEPA tariffs, and AD/CVD orders. 
• Strengthen supplier due diligence and forced labor compliance controls. 

Key Takeaway 

July 24, 2026 marks a significant transition in U.S. trade policy. While new Section 301 duties of 10% or 12.5% are now in effect for imports from 60 economies, the simultaneous expiration of Section 122 tariffs may offset some of the impact. Companies should conduct a product-by-product review to determine their actual duty exposure and identify potential opportunities under the broad exclusions available for aerospace, automotive, pharmaceutical, semiconductor, metal, and North American supply chains. 

How Crane Trade Consulting Can Help 

Crane Trade Consulting can support importers with HTS classification reviews, tariff exposure assessments, country-of-origin analysis, landed-cost modeling, FTZ planning, duty drawback evaluations, sourcing strategy reviews, supply chain impact assessments, compliance and implementation planning related to the new Section 301 measures. 

Our team can help organizations evaluate the applicability of exclusions, quantify duty exposure, and identify mitigation opportunities across global supply chains. 

Disclaimer 

This advisory is provided for informational purposes only and does not constitute legal advice. The information is based on publicly available government sources and USTR announcements as of July 24, 2026. Trade measures and implementing instructions may be modified, clarified, or supplemented by subsequent government actions. Importers should consult qualified legal counsel and trade compliance professionals before making decisions based on evolving trade policy developments. 

New Section 301 tariffs are now in effect. Do you know your actual duty exposure? Let Crane Trade Consulting help you evaluate tariff impacts, identify exclusions, and develop cost-mitigation strategies.

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