On June 2, 2026, USTR dropped the broadest Section 301 action in history — proposing new tariffs on imports from 60 countries, including your biggest trading partners. If you import from Canada, the EU, Mexico, Japan, South Korea, or virtually anywhere else, you have until July 6 to comment and until implementation to restructure. Here's your complete guide to what's coming, who's affected, and what to do right now.
On February 2026, the Supreme Court struck down the Trump administration's IEEPA tariffs in a decision that voided hundreds of billions in trade barriers overnight. Importers exhaled. Some even celebrated.
That celebration lasted exactly 98 days.
On June 2, 2026, Ambassador Jamieson Greer announced that USTR had completed Section 301 investigations into 60 economies and found every single one guilty of failing to prohibit or enforce bans on importing goods produced with forced labor. The proposed remedy: blanket tariffs of 10% to 12.5% on imports from all 60 countries. USTR didn't even try to hide the ball — officials described these investigations as a pathway to "replace" the invalidated IEEPA tariffs.
This isn't a targeted enforcement action against a few bad actors. This is a near-universal tariff on virtually all U.S. trading partners, wrapped in the language of human rights.
How We Got Here: From IEEPA to Section 301
The timeline matters because it reveals the strategy.
In February 2026, the Supreme Court ruled that the Trump administration had exceeded its authority by imposing broad tariffs under the International Emergency Economic Powers Act (IEEPA). The decision invalidated tariffs covering an enormous swath of U.S. imports.
The administration needed a new legal basis. It found one in Section 301 of the Trade Act of 1974 — the same statute used to impose tariffs on China in 2018. Section 301 authorizes USTR to take action against countries engaged in "unreasonable" trade practices that burden U.S. commerce.
On March 12, 2026, USTR initiated investigations into 60 countries, asking whether each had imposed and effectively enforced prohibitions on importing goods produced with forced labor. By June 2, just 82 days later, USTR had its answer: all 60 failed.
The speed matters. Traditional Section 301 investigations — like the original China probe in 2017-2018 — took over a year. These 60 investigations wrapped in under three months.
The Two-Tier Tariff Structure
USTR's findings divide the 60 economies into two categories, with different proposed tariff rates for each:
| Category | Countries | Finding | Proposed Tariff |
|---|---|---|---|
| Tier 1 — Laws exist, poorly enforced | Canada, EU, Ecuador, Indonesia, Mexico, Pakistan | Have a forced labor import prohibition but fail to effectively enforce it | 10% |
| Tier 2 — No laws at all | 54 remaining economies | Have neither imposed nor effectively enforced a forced labor import prohibition | 12.5% |
The Tier 2 list includes major sourcing countries like Bangladesh, Cambodia, Vietnam, India, Thailand, South Korea, Japan, Taiwan, Brazil, and dozens more. If you source from anywhere outside the United States, chances are your suppliers are in one of these 60 economies.
These tariffs stack. They would apply on top of existing duties, including Section 301 China tariffs, Section 232 metals tariffs, and normal Column 1 rates. An import from China already facing a 25% Section 301 tariff could see its effective rate climb to 37.5%.
What's Covered — and What's Not
The proposed tariffs would apply to products listed in Annex A of the Federal Register notice — a broad product list that USTR is still accepting comments on.
Key exclusions that have been announced:
- Section 232 products — steel, aluminum, copper, and derivatives already subject to Section 232 tariffs
- USMCA-compliant goods from Canada and Mexico (this is huge — but proving USMCA compliance requires proper documentation)
- CAFTA-DR textiles and apparel from Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, or Nicaragua that enter duty-free
- Informational materials (books, films, etc.)
- Donations and accompanied baggage
The USMCA exclusion means that goods from Canada and Mexico which meet USMCA rules of origin requirements would be exempt from the 10% tariff. But here's the catch: if your Canadian or Mexican imports don't qualify under USMCA — because they don't meet the regional value content or tariff shift requirements — they're exposed to the full 10%.
Why This Matters: The Real Business Impact
Let's do some math. The United States imported approximately $3.2 trillion in goods in 2025. Strip out domestic production and the handful of countries not covered, and you're looking at tariffs potentially affecting the vast majority of U.S. imports.
For a mid-size importer bringing in $50 million in goods annually from a Tier 2 country:
| Scenario | Current Duty (Example) | + Proposed 301 | New Total | Annual Cost Increase |
|---|---|---|---|---|
| Consumer electronics from Vietnam | 0% (MFN) | +12.5% | 12.5% | +$6.25M |
| Auto parts from Japan | 2.5% | +12.5% | 15% | +$6.25M |
| Apparel from Bangladesh | 16% | +12.5% | 28.5% | +$6.25M |
| Machinery from Germany (EU) | 3% | +10% | 13% | +$5M |
These numbers assume full product coverage under Annex A. Your actual exposure depends on whether your specific HTS codes are listed.
The Legal Vulnerability Nobody's Talking About
Here's something your competitors might miss: these tariffs may not survive a court challenge.
Section 301 was designed for targeted actions against specific unfair trade practices — not universal tariffs on 60 countries simultaneously. Legal experts at Orrick noted that "these Section 301 tariffs may be vulnerable to court challenge" given the unprecedented breadth of the action.
The argument is straightforward: can USTR really claim that 60 different countries all commit the same "unreasonable" trade practice, investigate them all in 82 days, and impose near-identical tariffs — all while explicitly stating the goal is to "replace" tariffs the Supreme Court just struck down?
This matters for your planning horizon. If you're making long-term supply chain decisions, factor in the possibility that these tariffs could face the same fate as IEEPA — struck down by a court within 12-18 months.
The Comment Period: Your Window to Act
USTR is accepting public comments, and the deadlines are tight:
| Deadline | Action Required |
|---|---|
| June 22, 2026 | Submit requests to appear at public hearing + summary of testimony |
| July 6, 2026 | Written comments on proposed action due |
| July 7, 2026 | Public hearings begin (USITC, 500 E Street SW, Washington, D.C.) |
| 5 days after hearings close | Post-hearing rebuttal comments due |
Written comments are your most powerful tool. USTR specifically asks for input on:
- Whether specific products should be excluded from the tariff lists
- The appropriate tariff rate
- Whether a proposed textile mechanism should extend to other sectors
- The relative market opportunities for U.S. and foreign products
If you have products that would face severe disruption, this is your chance to request a product exclusion. Companies that participated in the original Section 301 China tariff exclusion process secured billions in duty relief — the same opportunity exists here.
What to Do Right Now: A 5-Step Action Plan
1. Map your exposure immediately — Pull your import data for the last 12 months. Identify every HTS code you import, the country of origin, and whether that country is in the Tier 1 or Tier 2 group. Calculate your potential duty increase.
2. Audit your USMCA claims — If you import from Canada or Mexico, USMCA-compliant goods are excluded. Verify that your certificates of origin are current, your regional value content calculations are documented, and your tariff shift analyses are defensible. A sloppy USMCA claim that was "good enough" before is now potentially worth 10% of the value of every shipment.
3. File comments by July 6 — If any of your products would face severe supply disruption or if there's no domestic alternative, submit a written comment requesting exclusion. Be specific: cite your HTS codes, annual import volumes, the lack of domestic alternatives, and downstream economic impact.
4. Evaluate supply chain shifts — For Tier 2 countries facing 12.5%, determine whether shifting to a Tier 1 source (10%) or a USMCA-compliant source (0%) makes economic sense. A 2.5% differential alone rarely justifies relocation, but combined with other tariff exposure it might tip the equation.
5. Monitor the legal landscape — Trade associations are almost certainly preparing legal challenges. Track developments at the Court of International Trade. Don't make irreversible supply chain decisions if the legal foundation of these tariffs is questionable.
What's Coming Next
These forced labor tariffs are only half the story. USTR simultaneously has an ongoing Section 301 investigation into "structural excess capacity" in the manufacturing sectors of 16 trading partners — primarily targeting China, but also other major manufacturing economies. That investigation could result in additional tariffs layered on top of these.
The administration has also signaled interest in a government-to-government trade management mechanism with China — essentially a bilateral quota system. If implemented, this could reshape China trade flows in ways that make the current tariff regime look simple.
Key dates to watch:
- July 7, 2026: Public hearings — watch for signals about product exclusion appetite
- Late July/August 2026: Expected final determination
- Fall 2026: Likely implementation date (based on precedent from 2018 Section 301 China timeline)
- Ongoing: Section 301 excess capacity investigation results (16 countries)
The Bottom Line
This action is extraordinary not because 10-12.5% is a devastating rate in isolation — it's because it's universal. When you combine forced labor tariffs with Section 232 metals tariffs, existing Section 301 China tariffs, and whatever comes from the excess capacity investigation, you get a stacking effect that makes U.S. import costs genuinely unpredictable.
The importers who will navigate this best are the ones who map their exposure now, file comments before July 6, and build flexibility into their sourcing — without overreacting to tariffs that may not survive legal challenge.
TariffLens tracks duty rate changes across all 60 affected economies and can model your exposure under proposed tariff scenarios — so you can run the numbers before the rates are final.
This article is for informational purposes only and does not constitute legal, tax, or customs advice. Consult a licensed customs broker or trade attorney for guidance specific to your situation.