Executive Summary
The USTR’s July 28 notice imposes additional Section 301 duties on products of 60 investigated economies, effective for entries and warehouse withdrawals from July 24, 2026.
The basic rates are 10 percent for 17 named economies, capped at 10 percent or 12.5 percent including MFN duty for five others, and 12.5 percent for all remaining investigated economies.
The rate is not the whole analysis: Annex I and Annex II provide product exemptions, and certain Canada and Mexico goods qualifying for USMCA treatment are also excluded.
The July 24 start has a narrow in-transit exception, while a further HTSUS amendment for patented pharmaceutical articles is scheduled for July 31.
Section 301 forced labor tariffs began applying to covered goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on July 24, 2026. In its July 28 USTR notice, the Trade Representative imposed additional duties on products of 60 investigated economies, following the President’s July 23 memorandum.
The notice sets country-specific rates and exclusions, with a narrow exception for certain goods already in transit. It also schedules a further HTSUS amendment for July 31. Importers should assess the product’s origin, classification, entry date and eligibility for a listed exemption before determining the additional duty.
What Are the Section 301 Forced Labor Tariff Rates?
The notice sets 10 percent additional duties for products of Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, and the United Kingdom, unless an exemption applies. The duty is additional to ordinary customs duties and, except as the notice specifies, other additional duties. The country’s rate therefore does not by itself determine the total amount due. (USTR notice, section II.A)
For the European Union and Taiwan, the Section 301 duty brings the combined MFN and Section 301 rate to 10 percent when the MFN rate is below 10 percent; when the MFN rate is at least 10 percent, the Section 301 duty is zero. For Japan, South Korea and Switzerland, the equivalent cap is 12.5 percent. All other investigated economies face 12.5 percent, subject to exemptions.
These are product-of-economy rules, not a list limited to goods made with forced labor. USTR says the action reaches goods without regard to whether the specific goods or sector were involved in the investigated practices. Confirm origin and the applicable country provision rather than relying only on a supplier’s description of the product. (USTR notice, sections II.A and III.B)
Which Products Are Exempt From These Section 301 Duties?
The exclusions are set out in Annex I and Annex II. Annex I includes broad categories, including specified goods subject to Section 232 duties, civil aircraft and qualifying aircraft parts, articles for use in pharmaceutical applications, and certain vehicles, vehicle parts, wood products and semiconductor articles. The note also excludes personal-use products in accompanied baggage and, subject to stated exceptions, goods properly entered under a provision of chapter 98. Chapter 98 exclusions do not apply to the enumerated repair, alteration, processing or foreign-assembly provisions; for those entries, the Section 301 duty applies to specified values. (USTR notice, Annex I, U.S. note 52)
Annex II provides additional HTSUS provisions and country-specific exclusions. Examples of product categories added to the exemption list include certain animal products, seeds, agricultural inputs, pig iron, metal scrap, pharmaceuticals and ingredients, worn clothing, and certain art and antiques. Some exemptions cover only a described product or use, not every item classified in the cited provision. Annex II says its product descriptions are informational and do not delimit the action’s scope; refer classification questions to CBP.
Canada and Mexico have specific exclusions for goods entered free of duty under USMCA. Certain qualifying textile and apparel goods from specified Central American countries also have an exclusion when entered free of duty under the applicable trade agreement. Check the precise HTSUS provision, origin and entry claim. A product is not exempt merely because it resembles an item named in an annex. (USTR notice, Annex I and Annex II)
When Do Bangladesh Textile Tariff Quotas Take Effect?
The President directed USTR to establish tariff-rate quotas for Bangladesh, Cambodia, Indonesia and Malaysia when USTR determines that they are feasible. The quotas are to have an initial duration of three years and allow a specified volume of textile and apparel goods to enter free of the Section 301 duties, based on each economy’s importation of U.S. textile goods and cotton. Until a quota is established, the applicable Section 301 duty, which is 10 percent for these four economies, applies to the specific textile and apparel imports that will be covered by the quotas. (USTR notice, section II.A)
The notice does not establish quota volumes or an effective date. USTR says it will issue a separate Federal Register notice on establishment and the effective date. The quota direction is not a currently available exemption, so do not claim quota treatment before the implementing notice applies.
Which Entry Dates Trigger the New Section 301 Duties?
- July 23, 2026: Presidential memorandum. The President directed USTR to impose the rates and exemptions described in the notice.
- July 24, 2026, at 12:01 a.m. eastern time: Duty start. The additional rates apply to goods entered for consumption or withdrawn from warehouse for consumption on or after this time.
- July 28, 2026, at 12:01 a.m. eastern time: Transit exception cutoff. Goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before the July 24 start are not subject to the duty if entered or withdrawn before this cutoff.
- July 28, 2026: Notice published. USTR published the notice establishing the action and its effective date.
- July 31, 2026: Scheduled HTSUS amendment. The notice schedules a change to the description of heading 9903.05.90 and the related note to add patented pharmaceutical articles to the specified exclusion. (USTR notice, DATES and Annex I)
How Should Importers Update Section 301 Entry Review?
Identify affected entries. Review entries and warehouse withdrawals from the July 24 start by product origin and date. Flag goods that may fall within the limited in-transit exception and retain records supporting vessel loading, transit and entry timing.
Validate classification and exclusions. Compare each HTSUS classification with Annex I and the relevant country-specific parts of Annex II. Confirm that any claimed use-based, trade-agreement or chapter 98 exclusion is supported by the entry facts and required claim.
Recalculate duty exposure. Apply the correct country rate and, for the European Union, Taiwan, Japan, South Korea or Switzerland, determine the relevant MFN rate before calculating the capped Section 301 amount. Keep other applicable duties in the calculation unless the notice expressly excludes them.
Coordinate upcoming changes. Update entry instructions for the July 31 amendment and monitor for USTR’s separate notice establishing the textile quotas. Do not treat those future quotas as effective before the announced effective date.
What Remains Unresolved in the Section 301 Tariff Notice?
The notice does not provide the textile quota volumes, allocation mechanics or effective dates. USTR says those details will appear in a separate notice after it determines the quotas are feasible. The notice also directs importers to CBP for questions about the scope of particular HTSUS provisions, so a product description alone may not resolve an uncertain classification or exemption claim.
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