New Section 301 Forced Labor Tariff Fully in Effect
The Office of the U.S. Trade Representative (USTR) implemented new Section 301 forced labor tariffs on imports from 60 trading partners, effective for merchandise arriving and entered for consumption, or withdrawn from warehouse for consumption, on or after July 24, 2026.
The new tariffs generally impose an additional 10% or 12.5% ad valorem duty, depending on the country of origin and the importing country’s forced labor enforcement regime. Certain products, including many goods already subject to Section 232 tariffs, goods eligible for preferential tariff treatment under the U.S.-Mexico-Canada Agreement (USMCA), as well as specified energy, agricultural and other exempt products, are excluded from the new Section 301 duties.
Tariffs and other actions taken under Section 301 terminate after four years unless a petitioner or domestic industry representative requests continuation, in which case USTR may extend the action. This means that this new Section 301 may be in place indefinitely, although a coalition of 25 states has filed suit in the U.S. Court of International Trade (CIT), arguing that the Trump administration’s new 10% and 12.5% Section 301 tariffs unlawfully attempt to replace earlier tariffs that the Supreme Court struck down, and that the forced labor justification is merely a pretext for broad import duties. The administration maintains the tariffs are lawful under Section 301 and necessary to combat forced labor in global supply chains.
CBP Updates Post-Summary Correction Processing Requirements
Effective Aug. 5, 2026, Customs and Border Protection (CBP) is implementing several important changes to the processing of post-summary corrections (PSCs). These modifications were announced in Federal Register Notice 91 FR 41053 and affect how additional duties, taxes and fees must be paid.
- Electronic payment required: Beginning Aug. 5, 2026, any increase in duties, taxes or fees resulting from a PSC must be paid electronically through an automated clearing house (ACH). Payment by check or cash will no longer be accepted.
- Full payment required: When filing a PSC that increases duties, taxes or fees, the filer must either pay the full amount due at the time the PSC is submitted or wait until CBP issues a bill at liquidation. Partial payments are no longer permitted. In addition, if payment is deferred until liquidation, the Automated Commercial Environment (ACE) will not allow any subsequent PSCs to be filed against that entry until the outstanding amount has been paid.
- Interest: Interest associated with additional duties cannot be paid before liquidation. CBP will issue a separate bill for any interest due after liquidation.
43 Companies Added to UFLPA Entity List
On July 31, 2026, the Department of Homeland Security (DHS) announced the addition of 43 companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List.
This marks the largest single expansion of the UFLPA Entity List since the program’s inception, bringing the total number of listed entities to 187. The newly designated companies are involved in the production of aluminum, apparel, copper, cotton, tomatoes and various downstream products.
Effective Aug. 3, 2026, goods produced by these entities are prohibited from entering the United States unless the importer rebuts the UFLPA’s presumption by demonstrating that the merchandise was not produced wholly or in part with forced labor.
Commerce Proposes Expanding Section 232 Tariffs To Additional Steel, Aluminum, and Copper Derivative Products
The Department of Commerce’s Bureau of Industry and Security (BIS) has published a proposed rule that would expand the scope of Section 232 tariffs to include 14 additional derivative products containing steel, aluminum and copper.
The proposed expansion covers a variety of imported products, including aluminum powder, brass wind musical instruments and related parts, welding machine parts, floor safes, certain electric conductor cables, fire extinguishers, heat exchanger parts, hydraulic engine and motor parts, self-propelled cranes, mobile lifting frames, straddle carriers and various types of trailers.
Under the proposal, most newly covered derivative products would become subject to a 25% Section 232 tariff. Certain heavy equipment, including self-propelled cranes, mobile lifting frames, straddle carriers and specified trailers, would instead be subject to a 15% Section 232 tariff.
The proposed rule has not yet been finalized. Importers of affected products should review the covered Harmonized Tariff Schedule of the United States (HTSUS) classifications and consider the potential impact on future imports if the rule is adopted.
