A new Section 301 tariff regime tied to forced-labor enforcement concerns took effect this month, applying a two-tiered structure across imports from 60 economies — one of the broadest country-scope trade actions of the year.
Why 'Two-Tiered' Matters
Unlike a flat across-the-board rate, a tiered structure means the applicable duty depends on where a country falls within the enforcement framework — making a single blanket compliance check insufficient. The same product sourced from two different countries on the list can face meaningfully different treatment.
What to Check Immediately
- Whether each of your sourcing countries appears on the 60-economy list, and if so, which tier applies
- Whether your supply chain has documentation supporting labor sourcing practices, since forced-labor enforcement actions often require affirmative proof of compliant sourcing, not just an absence of evidence otherwise
- Whether any of your existing suppliers have already been named in related enforcement actions, which can trigger extra scrutiny beyond the tariff itself
This Is Broader Than a Typical Section 301 Action
Most Section 301 actions in recent years have targeted a handful of countries or specific product categories. A 60-country scope means far more importers need to check exposure than with prior actions — this isn't limited to companies sourcing from one or two traditionally scrutinized countries.
A 60-country list means most import operations have at least one affected lane, even ones that assumed forced-labor enforcement was someone else's problem.