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USTR Opens Sweeping Section 301 Probes Into Forced‑Labor Enforcement by 60 Trading Partners

The move positions Section 301 as the administration’s durable basis for potential trade actions after the Supreme Court curtailed IEEPA tariff authority.

Overview

  • The investigations will examine whether foreign governments’ failures to ban and enforce prohibitions on goods made with forced labor are unreasonable or discriminatory and burden or restrict U.S. commerce under the Trade Act.
  • The scope covers the European Union plus 59 countries, including China, the United Kingdom, Canada, Mexico, Japan, South Korea, India, Australia, and Brazil, with USTR requesting consultations with each government.
  • The public docket opens March 18, written comments and hearing requests are due April 15, hearings are scheduled for April 28–May 1, and rebuttal comments are due seven days after the hearings conclude.
  • If USTR finds the practices actionable, the administration could impose tariffs or other trade measures on products from any or all of the economies under review, offering a path to longer‑term remedies as the Section 122 surcharge sunsets in late July.
  • USTR cites ILO and U.S. Department of Labor data showing persistent forced labor that taints supply chains in sectors such as textiles, critical minerals, fish products, and palm oil, generating an estimated $63.9 billion in annual profits, while noting some partners have rules that may lack effective enforcement.