Administration Imposes Broad Forced-Labor Section 301 Tariffs as Section 122 Surcharge Expires

Short summary

The Administration imposed Section 301 tariffs of 10% to 12.5% on goods from 60 economies that failed to enforce forced-labor import bans, replacing the expired Section 122 surcharge. The final action adds 471 product exclusions, 13 country-specific exclusion lists, and MFN-based tariff floors for the EU, Japan, South Korea, Taiwan, and Switzerland. Importers must analyze tariff liability separately from admissibility under existing forced-labor laws, as a clean supply chain does not eliminate the duty.

• •Section 301 tariffs of 10-12.5% imposed on 60 economies for failing to enforce forced-labor import bans
• •Final action adds 471 product exclusions and MFN-based tariff floors for key trading partners
• •Tariff liability is separate from admissibility — paying the duty does not protect goods from forced-labor detention
• •Litigation expected but Section 301 actions have historically been upheld; USTR included severability provisions

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