Effective July 24, 2026
The U.S. Customs and Border Protection (CBP) has begun implementing a new Section 301 Forced Labor trade action following a determination by the Office of the U.S. Trade Representative (USTR).
If your company exports products to the United States or serves as the U.S. Importer of Record, these new requirements may affect your imports.
This article provides a summary of the new requirements and highlights what importers should review before importing goods into the United States.
Beginning July 24, 2026, certain products imported into the United States may be subject to an additional duty of 10% or 12.5%, depending on the country of origin.
The additional duties apply to products from 60 countries and economies identified by the USTR.
It is important to note that this is a new Section 301 trade measure. It does not replace the Uyghur Forced Labor Prevention Act (UFLPA). UFLPA enforcement remains in effect.
These new duties may affect:
If your products are imported into the United States, you should determine whether they are subject to these new requirements.
The new duties apply to imports from 60 countries and economies, including:
…and many others.
Depending on the country, the additional duty is 10% or 12.5%.
There is an important exception for many shipments from Mexico and Canada.
According to CBP guidance, products that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement (USMCA) are generally exempt from these new Section 301 duties.
This means that if your products:
the additional Section 301 duty generally should not apply.
Products that do not qualify under the USMCA may still be subject to the new duties.
Importers of products from China should be aware that certain entries may require two separate Section 301 Chapter 99 classifications.
Importers should work closely with their customs broker to ensure entries are filed correctly.
Yes.
CBP has identified several products that are generally excluded from these new duties, including many:
Additional country-specific exemptions are also available for certain products.
If you import goods into the United States, we recommend that you:
Determine whether your products originate in one of the countries covered by the new Section 301 action.
If your products originate in Mexico or Canada, confirm whether they qualify for USMCA preferential treatment.
Ensure the appropriate HTSUS classification and Chapter 99 tariff numbers are being declared.
These new duties do not replace other trade remedies. Depending on the product, Section 232, Section 201, AD/CVD, or other duties may also apply.
Providing accurate product information before shipment can help avoid delays and filing errors.
Navigating new trade measures can be challenging, especially while implementation guidance continues to evolve.
Our Compliance Team can assist with:
Whether you are a U.S. importer, a foreign manufacturer, or an international exporter, our team is available to help you understand how these new requirements may affect your business.
The implementation of the new Section 301 Forced Labor duties represents another important change in U.S. trade compliance.
Because these duties depend on several factors—including country of origin, tariff classification, USMCA eligibility, and other applicable exemptions—it is important to review each shipment individually before importation.
Early planning and proper documentation can help minimize delays, unexpected duties, and compliance issues.
If you have questions about your products or upcoming shipments, the J.O. Alvarez Compliance Team is here to help.
For additional information, please refer to the official guidance issued by U.S. Customs and Border Protection (CBP) and the Office of the U.S. Trade Representative (USTR):
This article is provided for informational purposes only and is based on guidance published by U.S. Customs and Border Protection (CBP) and the Office of the U.S. Trade Representative (USTR) as of the date of publication. Because implementation of this trade measure is ongoing, additional guidance, system updates, or implementation instructions may be issued. The applicability of these duties depends on the specific facts of each import transaction, including the country of origin, tariff classification, eligibility for free trade agreements, and any applicable exemptions. Each shipment should be evaluated individually. Importers are encouraged to consult with their customs broker or trade compliance advisor regarding the application of these requirements to their specific imports.
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