Section 301 Forced Labor Tariffs: What Actually Took Effect July 24

The Section 301 forced labor tariffs USTR proposed on June 2, 2026 are now in effect. As of 12:01 a.m. ET on July 24, 2026, additional duties of 10% or 12.5% apply to imports from 60 economies that USTR determined have failed to prohibit or meaningfully enforce bans on goods made with forced labor.

The final action differs from the proposal in two ways that matter operationally: the tier assignment changed for a handful of countries, and the action added a combined rate structure for five major trading partners. That second change significantly affects how the duty is calculated for imports from the EU, Japan, South Korea, Switzerland, and Taiwan.

What's in the Final Action

The two-rate structure from the proposal carried through. The split:

10% tier covers economies with an existing forced-labor import prohibition, a binding commitment through an Agreement on Reciprocal Trade, or a partial regime USTR found sufficient. That list: Canada, Ecuador, the European Union, Indonesia, Mexico, Pakistan, the United Kingdom, Argentina, Bangladesh, Cambodia, El Salvador, Guatemala, Malaysia, and Taiwan.

12.5% tier covers all other 46 economies, including China, India, Japan, South Korea, Vietnam, Australia, Brazil, Singapore, Switzerland, Norway, the Philippines, and Thailand.

One notable final placement: Taiwan landed in the 10% tier. Through the comment period this wasn't certain; Taiwan was initially proposed at 12.5%. USTR found Taiwan's policy commitments on forced-labor goods sufficient to qualify for the lower rate.

The Combined Rate Structure

This is the key addition in the final action that wasn't in the June proposal. For five trading partners (the EU, Japan, South Korea, Switzerland, and Taiwan), the duty doesn't apply as a flat additional percentage on top of the MFN rate. Instead, USTR set a combined MFN-plus-Section-301 target rate:

EU and Taiwan: combined target of 10%. If the column 1 general rate on a specific product already equals or exceeds 10%, no Section 301 increment is assessed. If the MFN rate is below 10%, the Section 301 duty brings the total up to 10%.
Japan, South Korea, and Switzerland: combined target of 12.5%. Same mechanics.

In practice this means the actual Section 301 increment varies by product. EU pharmaceutical products, which generally enter at 0% MFN under longstanding tariff commitments, now face a 10% Section 301 addition to reach the 10% combined target. EU industrial goods already dutiable at 12–15% MFN face zero Section 301 increment on this action: the MFN rate already clears the threshold.

Japanese consumer electronics at 0% MFN face the full 12.5% increment. Japanese precision machinery dutiable at 4.4% MFN faces an 8.1% increment (to reach the 12.5% combined rate). Auto parts from Japan at 2.5% MFN face 10%.

This product-by-product variation is why classifying the exact HTS code matters here. The entry can't be filed with a blanket "12.5% on all Japanese goods" assumption. Some product lines face a smaller increment; some face none at all.

The IEEPA Context

These tariffs land differently than they would have six months ago.

On February 20, 2026, the Supreme Court ruled in Learning Resources, Inc. v. Trump, No. 24-1287, that IEEPA doesn't authorize tariff imposition. That decision vacated the April 2025 "Liberation Day" reciprocal tariffs, the broad additional duties that had applied to virtually every US import from most countries. Importers have been working through IEEPA refund processes since then (see: IEEPA tariff refund claims under CAPE).

The Section 301 forced labor action fills part of that space. India, Vietnam, Thailand, the Philippines, and Indonesia, which had carried Liberation Day reciprocal tariffs before the IEEPA decision, now face 10% or 12.5% forced labor duties instead. Those numbers are substantially lower than the Liberation Day rates were (26% for India, 46% for Vietnam under the original schedule), but they're not zero. Supply chains that moved to those origins specifically to escape Liberation Day rates now face a floor, and that floor took effect July 24.

For Chinese-origin goods, this story is different. The China Liberation Day tariffs were IEEPA-based and are now vacated, but Chinese goods still carry the original Section 301 China tariffs under Lists 1–4A because those were imposed under Section 301 authority, not IEEPA. What's new for China as of July 24 is the forced labor tariff on top.

How It Stacks on Chinese-Origin Goods

Section 301 duties stack. CBP CSMS message #69326983, issued to guide brokers on the July 24 implementation, confirms that Chinese-origin goods subject to existing Section 301 actions also pay the new forced labor duty — there's no offset or substitution.

The effective rate for a Chinese-origin entry is now:

Column 1 MFN rate + existing Section 301 List rate (7.5%–25%) + Forced Labor 301 (12.5%)

A product covered under Lists 1 or 2 at the 25% rate, entering at a 3% MFN rate: 3% + 25% + 12.5% = 40.5% combined

A product covered under List 4A at the 7.5% rate, entering at 5% MFN: 5% + 7.5% + 12.5% = 25% combined

A Chinese-origin product not covered by any existing Section 301 list (these exist in some specialty categories): MFN rate + 12.5% forced labor

Plus any applicable AD/CVD margins, which are assessed separately and also stack.

The forced labor increment doesn't move the needle the same way for China as it does for other origins, because the existing Section 301 rates were already high. But 12.5% on top of 7.5% (List 4A) is a 167% proportional increase in additional tariff burden for that tier. It's not nothing.

What to Do Now

Get the exact Section 301 increment for your key HTS codes from EU, Japan, Korean, Swiss, or Taiwanese suppliers. The combined rate structure means you can't generalize. Pull the column 1 MFN rate for each code and compare against the 10% or 12.5% threshold. Only the delta is assessed. Some products face the full increment; others face partial or zero increment.

Recalculate landed costs for all non-excluded origins. For supply chains that had been moving work from China to Vietnam, India, or Thailand in response to China's Section 301 rates, those alternatives now carry 12.5% as well. The rate differential between Chinese-origin and Vietnamese-origin goods narrowed materially as of July 24.

Verify Chapter 99 classifications for Chinese entries. Entries for Chinese-origin goods that were already using a Chapter 99 List subheading need to add the applicable forced labor Chapter 99 subheading as well. Both must appear on the entry. Brokers should have updated classification setups by now, but verify before your next entry.

Check exclusions. The final action includes product-specific exclusions. Review the USTR Federal Register notice for any exclusions applicable to your HTS codes.

The HTS lookup tool shows the current full duty stack for any HTS code and country of origin, including the forced labor increment layered on existing Section 301 rates.

Key Takeaways

Section 301 forced labor tariffs of 10% or 12.5% took effect at 12:01 a.m. ET on July 24, 2026, covering 60 economies representing 99.4% of US imports.
Five trading partners have a combined rate structure: the EU and Taiwan target 10% combined (MFN + Section 301); Japan, South Korea, and Switzerland target 12.5% combined. If MFN rates already clear the threshold, no Section 301 increment applies on that product.
The Section 301 increment varies by product for these five partners — calculate per HTS code, not per country.
China pays a flat additional 12.5% on top of existing List 1–4A Section 301 rates and column 1 MFN. CBP CSMS #69326983 confirms both apply simultaneously.
With IEEPA tariffs vacated by the Supreme Court, Section 301 is now the primary additional duty vehicle for most non-FTA origins. India, Vietnam, Thailand, and Indonesia (formerly subject to Liberation Day IEEPA rates) now face 10–12.5% through this action instead.
Both the applicable List subheading and the new forced labor Chapter 99 subheading must appear on Chinese-origin entries. Coordinate with your broker.

Getting the full Section 301 stack right across origins requires knowing the specific List, forced labor, and MFN rates for each HTS code. TariffClassify maps the complete duty picture for any product. Look up an HTS code.