Disclaimer: This alert is provided for general educational purposes and is not legal advice. Classification, country of origin, exemption eligibility, tariff treatment, and admissibility must be evaluated using the facts of each transaction and the most current CBP, USTR, and HTSUS guidance.

The United States has imposed new Section 301 tariffs on imports from 60 economies following investigations into whether those economies did not adopt or effectively enforce prohibitions on the importation of goods produced with forced labor.

The new tariffs generally apply based on the country of origin of the imported merchandise. They are not limited to products or shipments suspected of having been produced with forced labor.

Covered imports may be subject to:

An additional 10 percent duty;
An additional 12.5 percent duty; or
A special rate-cap calculation that brings the combined ordinary customs duty and new Section 301 duty to either 10 percent or 12.5 percent.

The duties apply to covered merchandise entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on July 24, 2026.

Key Rule & Requirement

Entries and warehouse withdrawals on or after 12:01 a.m. Eastern Time on July 24, 2026.
9903.05.85 may apply when merchandise was loaded onto a vessel at the port of loading and was in transit on the final mode of transit before 12:01 a.m. Eastern Time on July 24, 2026, and is entered for consumption or withdrawn from warehouse for consumption before 12:01 a.m. Eastern Time on July 28, 2026.

Both conditions are mandatory.
The new Section 301 duty generally stacks with ordinary customs duties, existing Section 301 duties, AD/CVD, and other applicable charges unless a specific exemption applies.
Products covered by identified Section 232 programs may be exempt from the new forced-labor Section 301 duty. The underlying Section 232 duty remains applicable.
FTA eligibility does not automatically eliminate the new tariff. Specific exemptions apply for qualifying USMCA goods and certain CAFTA-DR textile and apparel goods.
Covered goods admitted to an FTZ on or after the effective date must generally be admitted in privileged foreign status, unless eligible for admission in domestic status.

The in-transit language requires vessel loading at the port of loading, final transit before the effective time, and entry or warehouse withdrawal before the July 28 cutoff. The final notice also ties the FTZ requirement to the date the additional duty is imposed.

Scale of the Action

Investigated Economies - 60

Chapter 99 Headings - 101

Annex II Exclusion Rows - 5,304

Unique Explicit Base HTS Provisions - 4,070

The number of tariff provisions and exemption records makes product-by-product review essential. Importers should not assume that all products from the same country receive the same treatment.

Applicable Duty Rates

Additional 10% Duty

- Argentina
- Bangladesh
- Cambodia
- Canada
- Ecuador
- El Salvador
- Guatemala
- Honduras
- India
- Indonesia
- Jordan
- Malaysia
- Mexico
- Pakistan
- Sri Lanka
- Trinidad and Tobago
- United Kingdom

Additional 12.5% Duty

- Algeria
- Angola
- Australia
- The Bahamas
- Bahrain
- Brazil
- Chile
- China
- Colombia
- Costa Rica
- Dominican Republic
- Egypt
- Guyana
- Hong Kong
- Iraq
- Israel
- Kazakhstan
- Kuwait
- Libya
- Morocco
- New Zealand
- Nicaragua
- Nigeria
- Norway
- Oman
- Peru
- Philippines
- Qatar
- Russia
- Saudi Arabia
- Singapore
- South Africa
- Thailand
- Türkiye
- United Arab Emirates
- Uruguay
- Venezuela
- Vietnam

NOTE — China-origin merchandise: The new 12.5 percent duty may apply in addition to existing China Section 301 duties, ordinary customs duties, AD/CVD, and other applicable charges. An exemption under the new action must be established separately.

Special Rate-Cap Economies

The European Union, Taiwan, Japan, South Korea, and Switzerland use a rate-cap calculation instead of a flat additional-duty rate.

For the European Union and Taiwan, the ordinary customs duty and the new Section 301 duty generally combine to equal 10 percent.

For Japan, South Korea, and Switzerland, the ordinary customs duty and the new Section 301 duty generally combine to equal 12.5 percent.

For qualifying South Korean merchandise, the properly claimed KORUS Column 1-Special rate is used in determining the amount of additional duty required to reach the 12.5 percent combined rate.

Major Exemptions

The action contains broad general exemptions and thousands of country-specific product exclusions.

Potential exemptions include:

Products classified under specifically listed HTSUS provisions;
Specifically described agricultural, religious, essential-oil, beverage, and other products;
Qualifying civil aircraft and civil-aircraft parts;
Certain products actually intended for pharmaceutical applications;
Products covered by identified Section 232 programs;
Qualifying humanitarian donations;
Informational materials;
Personal-use articles in accompanied traveler baggage;
Qualifying USMCA goods of Canada and Mexico;
Certain qualifying CAFTA-DR textile and apparel goods; and
Country-specific products listed in Annex II.

An exemption marked “Ex” applies only to the product described in the applicable exclusion language. It does not exempt every product classified under the listed tariff provision.

The civil-aircraft exemption applies only to qualifying articles that meet the requirements of General Note 6. The pharmaceutical-use exemption requires both an identified tariff classification and actual intended use in a pharmaceutical application.

Section 232 Interaction

Products properly covered by the Section 232 programs identified in U.S. Note 52 may qualify for exemption from the new forced-labor Section 301 duty.

The exemption includes certain covered:

Steel and aluminum articles;
Copper articles;
Passenger vehicles, light trucks, and automotive parts;
Medium- and heavy-duty vehicles and parts;
Wood products; and
Semiconductor articles.

The exemption does not apply merely because a product contains steel, aluminum, copper, wood, or semiconductor content. The article must be covered by one of the identified Section 232 provisions.

The underlying Section 232 duty and any independently applicable China Section 301, AD/CVD, or ordinary customs duties remain applicable.

Pharmaceutical Expansion

Effective for entries and warehouse withdrawals on or after 12:01 a.m. Eastern Time on July 31, 2026, the exemption under 9903.05.90 also includes patented pharmaceutical articles covered by headings 9903.04.60 through 9903.04.66.

Existing Forced-Labor Enforcement Continues

The new tariff is separate from CBP’s existing forced-labor enforcement.

Payment of the new Section 301 duty does not:

Establish that a shipment is free from forced-labor concerns;
Satisfy an importer’s supply-chain due-diligence obligations;
Prevent detention under a Withhold Release Order;
Overcome the UFLPA rebuttable presumption; or
Make prohibited merchandise admissible.

Importers should continue reviewing suppliers, manufacturers, processors, and raw-material sources for forced-labor exposure.

Recommended Actions for Importers

Importers should take the following actions:

Identify products with a country of origin in any of the 60 covered economies.
Confirm the correct country of origin for products involving multicountry manufacturing or assembly.
Determine whether the product receives a 10 percent rate, 12.5 percent rate, rate-cap treatment, or an exemption.
Review the complete HTSUS classification against the general and country-specific exemption lists.
Confirm whether the merchandise is covered by an identified Section 232 program.
Review whether patented pharmaceutical articles qualify for the expanded 9903.05.90 exemption beginning July 31, 2026.
Validate any USMCA, KORUS, or CAFTA-DR claim.
Review vessel shipments that may qualify for 9903.05.85 and confirm that both in-transit conditions are satisfied.
Recalculate landed costs and review purchasing, pricing, and duty-responsibility provisions.
Review bonded-warehouse and FTZ inventory.
Continue forced-labor supply-chain due diligence.

Detailed Technical Review

For the complete country tables, Chapter 99 provisions, rate-cap calculations, exemption analysis, Annex II guidance, Chapter 98 rules, FTZ treatment, and official source references, see Juno Customs Solutions’ full technical review.

Juno Customs Solutions

Juno Customs Solutions can assist importers with tariff-stacking reviews, exemption screening, HTSUS and Chapter 99 analysis, Section 232 interaction, country-of-origin review, free-trade-agreement treatment, and landed-cost planning. For questions regarding these changes, please contact us at brokerage@junocustoms.com

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