Section 301 Forced Labor Import Tariffs: What Importers Need to Know
Section 122 tariffs expired today, and they’ve effectively been replaced by new Section 301 Forced Labor Import Tariffs. Here’s what we know so far, and what it means for your shipments.
What Changed
The details below, along with supporting documentation, were published late yesterday. We’re still evaluating how these changes will affect operations for our clients. Unlike the former Section 122 tariff, the new tariffs vary by both country of origin and HTS classification.
Countries Subject to the 12.5% Tariff
These 54 economies have been identified as failing to impose and effectively enforce a prohibition on the importation of goods produced with forced labor:
Algeria, Angola, Argentina, Australia, Bahamas, Bahrain, Bangladesh, Brazil, Cambodia, Chile, China, Colombia, Costa Rica, Dominican Republic, Egypt, El Salvador, Guatemala, Guyana, Honduras, Hong Kong, India, Iraq, Israel, Japan, Jordan, Kazakhstan, Kuwait, Libya, Malaysia, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, South Korea, Sri Lanka, Switzerland, Taiwan, Thailand, Trinidad and Tobago, Türkiye, United Arab Emirates, United Kingdom, Uruguay, Venezuela, and Vietnam.
Countries Subject to the 10% Tariff
These six economies have been identified as failing to effectively enforce a prohibition on the importation of goods produced with forced labor:
Canada, Ecuador, European Union, Indonesia, Mexico, and Pakistan.
Our Recommendation
Until the necessary programming updates are complete and we have a clearer picture of how these tariffs will apply operationally, our recommendation is: if you were previously budgeting for the 10% Section 122 tariff, plan on a rate of 10% to 12.5%, depending on country of origin. The specific rate that applies will ultimately depend on the HTS classifications listed in the attached documentation.
For full details, see the official Notice of Action: FLIP 301 Investigation Final Action FRN 7-23-26 FINAL.pdf
Questions?
We’re monitoring this closely and will share updates as the operational details become clearer. In the meantime, feel free to reach out with any questions — we’ll get back to you as soon as possible.
