New Forced-Labor Tariffs: What Importers Should Do Now

    Since July 24, 2026, a new Section 301 action adds 10% or 12.5% in duties on imports from about 60 economies — with no exclusion process to petition for relief. Here's what changed, whether it applies to your goods, and how to make sure you're not overpaying.

    Reviewed by the Strix licensed brokerage team (U.S. customs broker, filer code 8ND) · Last reviewed August 14, 2026

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    What Changed on July 24, 2026

    Effective 12:01 a.m. ET on July 24, 2026, the U.S. Trade Representative imposed new Section 301 duties on imports from roughly 60 economies, following investigations into whether those countries impose and enforce bans on goods made with forced labor. Unlike the earlier Section 122 surcharge, which expired automatically after 150 days, this action has no built-in expiration date. Most affected imports now carry an additional 10% or 12.5% ad valorem duty, layered on top of whatever duties already applied — standard MFN rates, existing Section 301 China tariffs, or other trade remedies.

    A short in-transit exception applied only to goods already loaded on a vessel before the effective date and entered for consumption by July 28, 2026. That window has closed. If your goods entered after July 28, 2026, from one of the affected economies, the new duty applies unless your product or origin qualifies for an exemption (see below).

    One detail that catches importers off guard: there's no exclusion request process for this action. Earlier Section 301 actions, like the 2018–2019 tariffs on Chinese goods, let importers petition USTR for product-specific exclusions. This action doesn't offer that path — the exemption list published with the final action is fixed. That makes getting your classification and origin analysis right at entry more important than ever, since there's no case-by-case appeal to fall back on later.

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    Does the New Forced-Labor Tariff Apply to My Imports?

    It depends on where your goods originate, what they're classified as, and whether they fall into one of several carve-outs. Here's the breakdown, in order of how often importers ask:

    Country of Origin

    The additional duty applies to imports from the roughly 60 economies named in the final action. If your supplier ships from a country not on that list, this action doesn't apply to your entries — though other duties (Section 301 China tariffs, Section 232, standard MFN rates) may still.

    The 471 Exempted HTS Subheadings

    USTR published a list of 471 exempted Harmonized Tariff Schedule (HTS — the classification code system CBP uses to assess duties) subheadings, covering raw materials, supply-chain-critical inputs, and goods that can't be sourced domestically in sufficient volume. If your product's HTS classification is on that list, it's exempt from the new duty regardless of origin. Checking your classification against the exemption list is the single highest-value thing an importer can do right now — misclassification here means either overpaying or under-declaring, and neither is a good outcome.

    USMCA and CAFTA-DR Qualifying Goods

    Goods that qualify for duty-free treatment under the United States-Mexico-Canada Agreement (USMCA) are fully exempt from this action, as are CAFTA-DR-qualifying textile and apparel goods from the six Central American and Caribbean countries covered by that agreement. "Qualifying" is the operative word — your goods need to actually meet the rules of origin under those agreements, not just ship from a member country.

    Section 232-Covered Articles

    Products already subject to Section 232 tariffs (steel, aluminum, and other designated articles) are exempt from the forced-labor 301 duty. These goods carry their own tariff treatment and aren't stacked with this action.

    MFN Rate Caps for Five Economies

    Imports from the European Union and Taiwan have their combined MFN-plus-Section-301 duty capped at 10%; imports from Japan, South Korea, and Switzerland are capped at 12.5%. If your product's existing MFN duty rate already meets or exceeds the cap, you may owe little or no additional Section 301 duty. This cap makes accurate classification even more valuable for shipments from those five economies — the wrong HTS code could mean paying a duty you don't actually owe.
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    What Importers Should Do Now

    1. 01

      Get Your Entries Filed Correctly

      Whether you self-file or use a broker, the entry needs the right HTS classification, the right origin determination, and the right exemption claim where one applies. Strix's self-filing software runs $30 per entry for importers who want to file themselves with our tools and support. For entries where you want a licensed customs broker handling classification and exemption claims directly, full brokerage runs $100–$250 per entry depending on complexity.
    2. 02

      Request an Exemption Review

      If you're not sure whether your goods fall under one of the 471 exempted subheadings, or whether your supply chain actually qualifies under USMCA or CAFTA-DR rules of origin, a licensed broker can review your classification and origin documentation before you file — or check entries you've already filed.
    3. 03

      Check Entries Filed Since July 24 for Overpayment

      If you've been paying the new duty since it took effect and later realize your goods should have qualified for an exemption, a Post Summary Correction (PSC) can fix an entry before it liquidates. PSCs have to be filed within specific windows tied to each entry's liquidation date, so the sooner you check, the more options you have. See our PSC filing guide for how the process works.
    4. 04

      Keep Records Refund-Ready

      Multiple lawsuits are pending before the Court of International Trade challenging this Section 301 action, including a complaint filed by 25 state attorneys general in August 2026. We can't predict how that litigation resolves or promise any refund outcome. What we can say: importers who kept clean, well-documented entries during the earlier IEEPA tariff dispute were the ones positioned to act quickly once the Supreme Court ruled and CBP opened its refund process. See our IEEPA CAPE refund page for how that played out. Accurate entries now put you in the same position if this litigation goes the same direction — without any guarantee that it will.
    5. 05

      Watch for Duty Stacking

      This 301 duty layers on top of other tariffs that may already apply to your goods — existing Section 301 China duties, standard MFN rates, or other trade remedies. Getting the classification and origin analysis right matters more now, because an error compounds across every duty line on the entry, not just this one.
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    Is This the Same as UFLPA? No — Here's the Difference

    It's an easy mix-up, since both deal with forced labor and both affect imports. But they're different programs with different mechanics:

    This Section 301 action is a tariff. It adds 10% or 12.5% in duty to entries from about 60 economies, based on whether those countries adequately ban forced-labor imports. It's assessed and paid at entry, like any other duty.

    UFLPA (the Uyghur Forced Labor Prevention Act) is a detention mechanism, not a tariff. It creates a rebuttable presumption that goods linked to Xinjiang, China, or to specific companies on the UFLPA Entity List, are made with forced labor and bars their entry unless the importer proves otherwise with clear and convincing evidence. CBP detains shipments it suspects fall under UFLPA — it doesn't just charge extra duty. The UFLPA Entity List expanded to 187 companies after DHS's August 2026 update, the largest single expansion since the list began. Once a shipment is detained under UFLPA, most are ultimately denied entry rather than released, based on CBP's published enforcement data.

    The two programs can overlap — goods from a listed UFLPA entity could also be subject to the Section 301 duty if they clear — but they're evaluated separately, with separate compliance steps. If you're dealing with a UFLPA detention rather than a 301 duty question, our UFLPA compliance guide covers that process in more detail.

    Forced-Labor Tariff FAQ

    It's a Section 301 duty of 10% or 12.5%, effective July 24, 2026, on imports from about 60 economies that USTR found don't adequately ban forced-labor imports. It's layered on top of existing duties and applies unless your goods qualify for one of the published exemptions.

    China is among the roughly 60 economies covered by this action, so the new duty can apply to Chinese-origin goods in addition to existing Section 301 China tariffs — unless your product falls under one of the 471 exempted HTS subheadings or another carve-out. A broker can confirm your specific classification and origin.

    Yes. Goods classified under one of 471 exempted HTS subheadings are exempt regardless of origin, as are USMCA-qualifying goods, CAFTA-DR-qualifying textile and apparel goods, and Section 232-covered articles. Five economies — the EU, Taiwan, Japan, South Korea, and Switzerland — also get an MFN rate cap that can reduce or eliminate the additional duty.

    No — unlike the 2018–2019 Section 301 China tariffs, this action does not include a case-by-case exclusion request process. The published exemption list (471 HTS subheadings, plus USMCA, CAFTA-DR, and Section 232 carve-outs) is fixed, which makes getting your classification and origin analysis right at entry the most important lever you have.

    No. This is a tariff — an added duty charged at entry. UFLPA is a detention mechanism that can block goods from entering the U.S. at all if they're linked to Xinjiang or a listed entity, regardless of any tariff. The two programs are evaluated separately, though a shipment could face both.

    If an entry hasn't liquidated yet, a Post Summary Correction (PSC) can fix the classification or exemption claim before it does. Filing windows are tied to each entry's liquidation date, so the sooner you check, the more options are available. A licensed broker can review your entries and confirm whether a PSC applies.

    Get a Licensed Broker on Your Forced-Labor Tariff Entries

    Whether you need help confirming an exemption, filing entries correctly going forward, or checking whether you've overpaid since July 24, a licensed customs broker can walk through your specific shipments with you.

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    Prefer to talk it through? Call (406) 922-6600.

    (406) 922-6600 · sales@strixsmart.com · Licensed Since 2006

    Related resources:

    UFLPA Compliance GuidePost Summary CorrectionsIEEPA CAPE Refund RecoverySection 122 Import SurchargeOur Brokerage Services