New Section 301 Tariffs on Imports from 60 Economies Now in Effect

USTR Imposes 10% or 12.5% Duties Over Forced-Labor: Exemptions for Food, Pharma and Aerospace Products

On July 24, 2026, the Office of the U.S. Trade Representative (USTR), at the direction of President Trump, took final action in its Section 301 investigations of 60 economies for their failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor. The action imposes additional tariffs on imports from the covered trading partners and took effect at 12:01 a.m. ET on July 24, 2026. The USTR fact sheet is available here.

Importers should assess which of their products originate in the covered countries and whether any exemption applies. Companies that do not import directly, but rely on international supply chains, should assess their vendors’ exposure to avoid cost and sourcing disruptions.

Multi-Tier Tariff Structure

• 10% additional duty: Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, the United Kingdom, and Trinidad and Tobago.
• 10% net of MFN rate: European Union or Taiwan: if the underlying rate (MFN) is less than 10% the sum of the underlying rate and this section 301 tariff will be 10%, no tariff if the underlying rate is more than 10%.
• 12.5% net of MFN rate: Japan, Korea, or Switzerland: if the underlying rate (MFN) is less than 12.5% the sum of the underlying rate and this section 301 tariff will be 12.5%, no tariff if the underlying rate is more than 12.5%.
• 12.5% additional duty: on imports from all other top 60 U.S. trading partners.
• Tariff rate quotas: will be imposed for textiles from Bangladesh, Cambodia, Indonesia, and Malaysia to encourage use of U.S. textiles and cotton in those countries.

Scope and Coverage

The action applies to the top 60 U.S. trading partners, which together account for approximately 99.4% of U.S. imports. It replaces the temporary across-the-board tariff previously imposed under Section 122 of the Trade Act, which expired on July 24, 2026.

Product Exemptions

• Products entered under the USMCA free trade agreement.
• Certain textile and apparel products entered under the CAFTA-DR free trade agreement.
• Articles and parts of articles subject to Section 232 tariffs.
• Certain products identified by USTR, including raw materials whose coverage could reduce domestic supply and goods that cannot be produced or sourced in sufficient quantities elsewhere including: beef, coffee, tea, bananas, oranges, tomatoes, pineapples, avocados.
• Certain products for the pharmaceutical, energy and aerospace industry are also exempt. There are also specific exemptions on a county by country basis.
• A complete list of exempt products is set out in the Federal Register notice.

Goods in Transit

Goods that were already loaded and in transit on their final mode of transport before July 24, 2026 may avoid the additional duty if they are entered for consumption before July 28, 2026.

What Importers Should Consider

• Identify the country of origin for each product line and determine the applicable tariff tier.
• Review the Federal Register annexes to confirm whether any of your products are exempt.
• Model the landed-cost impact of the additional 10% or 12.5% duty and review contracts and pricing accordingly.
• Evaluate the in-transit window for shipments currently en route.
• Monitor for the published Federal Register notice and any legal challenges that may affect implementation. If these tariffs are ultimately ruled invalid by the courts, importers may be able to recover them in the future (as with the IEEPA tariffs).

If you need assistance, please let us know. As a law office with a licensed customs brokerage, we help importers assess tariff exposure, secure refunds and drawback, evaluate country-of-origin and exemption questions, and respond to CBP enforcement. You can reach us at info@liebermanpllc.com or (202) 830-0300, or contact us here.