USTR Imposes Forced-Labor Tariffs on 60 Economies After Supreme Court Scrapped IEEPA Authority

WASHINGTON, The Office of the U.S. Trade Representative imposed new tariffs on imports from 60 countries effective July 24, anchoring a broad trade enforcement action on forced-labor law after the Supreme Court eliminated the White House's primary tariff tool earlier this year.

The duties, announced roughly seven hours before they took effect, landed at 12:01 a.m. Eastern time on July 24, the precise moment a stopgap global tariff under Section 122 of the Trade Act of 1974 expired, according to a Holland and Knight client alert reviewed by ETL Newswire.

The USTR initiated 60 investigations on March 12 under Section 301 of the Trade Act of 1974, according to a fact sheet published by the agency. The investigations examined whether trading partners had failed to prohibit imports made with forced labor. USTR found actionable conduct in all 60 cases.

The rate structure is tiered. Countries that have a forced-labor import prohibition on the books, Canada, Ecuador, the European Union, Indonesia, Mexico and Pakistan, face a 10% additional duty. The remaining 54 trading partners, which USTR determined have no such prohibition in place at all, face 12.5%, according to the Holland and Knight alert.

The USTR fact sheet put the scope plainly: the action covers the top 60 U.S. trade partners and reaches 99.4% of U.S. imports by value.

Ambassador Greer framed the move in generational terms. "The United States has had a forced labor import ban for nearly a century, and rigorously enforces it; it's well past time for our trading partners to do the same," he said in the USTR press release.

The new tariffs are the administration's most consequential tariff action since the Supreme Court's Feb. 20 ruling in Learning Resources, Inc. v. Trump, which held that the International Emergency Economic Powers Act does not authorize tariff imposition, according to an analysis published by Troutman Pepper Locke. That decision eliminated the legal basis for tariffs that had been the centerpiece of the administration's trade strategy. The Section 122 stopgap that followed was capped at 15% and limited to 150 days by statute, according to the Holland and Knight alert.

USTR received more than 1,600 written comments on the proposed tariffs and held three days of public hearings July 7 through 9, at which more than 100 witnesses testified, according to the USTR press release.

Following that comment period, USTR expanded its product exemption list by 471 Harmonized Tariff Schedule subheadings, covering raw materials, supply-chain-critical goods and products that cannot be sourced domestically in sufficient quantities, according to the Troutman Pepper Locke analysis. Goods entered free of duty under the U.S.-Mexico-Canada Agreement are fully exempt.

Opponents didn't wait long. A legal group representing importers filed suit in the U.S. Court of International Trade the day the tariffs took effect, according to the Holland and Knight alert. Legal analysts at the Congressional Research Service flagged that critics could invoke the major questions doctrine, arguing that conduct so widespread it captures nearly all U.S. imports may exceed what Section 301 authorizes, though proponents counter that Section 301, unlike IEEPA, explicitly authorizes tariffs, according to a CRS legal sidebar reviewed by ETL Newswire.

The administration separately launched a parallel Section 301 investigation into structural excess manufacturing capacity, which analysts and some administration officials have described as a vehicle for additional tariff coverage, according to the CRS sidebar.

Sources cited:
- USTR Fact Sheet, Section 301 Forced Labor Action (https://ustr.gov/about/policy-offices/press-office/fact-sheets/2026/july/fact-sheet-ustr-section-301-action-response-failure-60-economies-ban-imports-produced-forced-labor)
- USTR Press Release, USTR Takes Action in Forced Labor Section 301 Investigations (https://ustr.gov/about/policy-offices/press-office/press-releases/2026/july/ustr-takes-action-forced-labor-section-301-investigations)
- Holland & Knight, And the (Tariff) Beat Goes On (https://www.hklaw.com/en/insights/publications/2026/07/and-the-tariff-beat-goes-on)
- Troutman Pepper Locke, Forced Labor, Meet Section 301 (https://www.troutman.com/insights/forced-labor-meet-section-301-new-tariffs-target-60-of-americas-biggest-trading-partners/)
- Congressional Research Service, Legal Authority for Section 301 Tariffs (https://www.congress.gov/crs-product/LSB11460)
- Global Trade Alert, Forced-Labour Section 301 Tariffs Overview (https://globaltradealert.org/blog/forced-labour-section-301-final-action)