Importers Challenge New Forced-Labor Section 301 Tariffs

A new legal challenge has been filed against the recently implemented Forced-Labor Section 301 tariffs, but the tariffs remain in effect while the case proceeds.

On July 24, 2026, Burlap & Barrel, Inc. and Collective Horology LLC filed a proposed class action in the U.S. Court of International Trade (CIT), arguing that the Office of the United States Trade Representative (USTR) exceeded its authority when imposing the tariffs on imports from 60 economies.

The lawsuit alleges that:

  • USTR did not adequately connect the tariffs to specific foreign forced-labor practices.

  • The tariff action is arbitrary and capricious because similar duty rates apply across a broad range of products, including goods with no apparent connection to forced labor.

  • The tariffs exceed the authority granted under Section 301.

The plaintiffs are asking the court to:

  • Stop future collection of the tariffs.

  • Prevent liquidation of affected entries.

  • Require refunds of duties already paid.

  • Certify the case as a nationwide class action for affected importers.

What Importers Should Do

Although the lawsuit could eventually create refund opportunities, no court order has suspended the tariffs. Importers should continue to:

  • Report and pay all applicable Forced-Labor Section 301 duties.

  • Track affected entries and duty payments.

  • Monitor liquidation dates.

  • Preserve documentation in the event refunds become available through future litigation.

Juno Customs Solutions will continue monitoring this case and provide updates as significant developments occur.

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United States Imposes New Section 301 Tariffs on Imports from 60 Economies Over Forced-Labor Import-Ban Enforcement