The Office of the United States Trade Representative has announced findings and proposed action in 60 Section 301 investigations related to forced labor goods. For U.S. importers, this is not just another trade-policy headline. It is a signal that sourcing transparency, customs readiness, and landed-cost planning may become even more important in the months ahead.

On June 2, 2026, USTR determined that the acts, policies, and practices of 60 economies related to failures to impose or effectively enforce prohibitions on forced labor goods are actionable under Section 301 of the Trade Act of 1974. According to the official USTR announcement on the proposed Section 301 forced labor action, the proposed action includes additional duties on products from the investigated economies, subject to certain exclusions.

For importers, the key word is proposed. The action is not final yet. However, the comment period and hearing timeline are already moving. The Federal Register notice on the Section 301 investigations states that written comments are due July 6, 2026, and public hearings are scheduled to begin July 7, 2026.

That gives importers a narrow window to evaluate exposure, review product classifications, and prepare for possible cost and compliance impacts.

Why This Matters for U.S. Importers

The proposed Section 301 forced labor tariffs could affect importers across multiple industries, including apparel, consumer goods, automotive components, electronics, industrial materials, home goods, and other product categories connected to global sourcing.

USTR’s findings focus on whether trading partners have imposed and effectively enforced prohibitions on the importation of goods produced with forced labor. The Federal Register notice states that the proposed duties would apply to products of the investigated economies unless excluded under Annex A or other listed carveouts.

The proposal also identifies several potential exclusions, including certain products subject to Section 232 tariffs, some raw materials, informational materials, donations, accompanied baggage, USMCA-compliant goods of Canada or Mexico, and certain CAFTA-DR textile and apparel articles.

That means importers should not assume every product from a listed economy will be treated the same way. The impact will depend on product classification, country of origin, duty treatment, applicable trade programs, and whether the product falls within an exclusion.

This is exactly where proactive customs planning becomes critical.

Start With Your HTS Classifications

Before importers can estimate exposure to proposed tariffs, they need confidence in their HTS classifications.

A small classification error can create a large financial difference when additional duties are involved. Importers should review their active product database, confirm HTS codes, check product descriptions, and identify any tariff lines that may fall within proposed exclusions.

This is especially important for companies with high SKU counts, frequent supplier changes, or multiple product variations. If product records are outdated, incomplete, or inconsistent across purchasing, logistics, and customs teams, tariff exposure can be difficult to measure accurately.

GLC’s Customs Brokerage services help importers navigate classification, entry processing, customs documentation, and visibility across the import process. When policy shifts create uncertainty, accurate customs data becomes the foundation for better decisions.

Review Country of Origin and Supplier Mapping

The proposed Section 301 action is tied to products of specific economies. That makes country-of-origin accuracy essential.

Importers should review where products are manufactured, where materials are sourced, and whether supplier documentation supports the declared origin. For companies with multi-tier supply chains, this may require deeper coordination with vendors, factories, and purchasing teams.

Forced labor enforcement has already made supply chain visibility a higher priority for U.S. importers. Importers should review official CBP forced labor enforcement resources to better understand how documentation, supplier visibility, and due diligence can affect import compliance.

Companies with exposure to higher-risk sourcing regions should also review CBP’s UFLPA operational guidance for importers, which provides important context on forced labor enforcement expectations and importer responsibilities.

Even when an importer is not directly sourcing from a high-risk region, indirect exposure can exist through raw materials, components, subcontractors, or upstream suppliers. That is why documentation should go beyond the commercial invoice.

Recalculate Landed Costs Before the Final Action

Additional duties can affect margin, pricing, purchase orders, and sourcing decisions. A proposed 10% or 12.5% duty may not sound large in isolation, but the impact can become significant across container volumes, seasonal inventory, or low-margin product categories.

Importers should begin modeling several scenarios now:

What happens if the proposed duties become final?

Which SKUs are most exposed?

Can supplier contracts absorb or share the increased cost?

Are retail prices, customer agreements, or distributor margins flexible enough to adjust?

Could alternate sourcing, routing, or inventory timing reduce risk?

This is not only a customs issue. It is a supply chain planning issue.

GLC’s Freight Forwarding solutions support importers with ocean freight, air freight, trucking, customs coordination, and end-to-end logistics visibility. When policy changes affect landed costs, importers need logistics partners who can help them evaluate timing, routing, and execution with a clear operational lens.

Watch the Textile and Apparel Mechanism

The USTR proposal also includes a textile mechanism that could allow a certain volume of apparel and textile imports from certain economies to enter the United States at a reduced Section 301 tariff rate. According to the Federal Register notice, the reduced-duty volume would be tied to U.S. textile, cotton, and cotton product exports to the trading partner.

For apparel, retail, and textile importers, this could create an additional layer of planning. Duty exposure may depend not only on origin and classification, but also on product category, volume, sourcing history, and how the final mechanism is structured.

Companies in these sectors should monitor the final details closely and prepare to review supplier data, entry records, and product-level duty scenarios.

Prepare Documentation Before Cargo Moves

When trade policy changes quickly, importers that wait until cargo is already in transit often have fewer options.

Before placing new purchase orders, importers should confirm documentation requirements with suppliers. This includes commercial invoices, packing lists, product specifications, bills of materials, origin documentation, and any forced labor due diligence records that may be relevant.

Internal teams should also align on broker instructions, Incoterms, tariff responsibility, duty payment process, and escalation procedures if goods are delayed, detained, or subject to unexpected costs.

GLC’s Supply Chain Consulting services help companies evaluate risk, improve process visibility, and build more resilient import strategies. In a shifting regulatory environment, the best time to improve documentation workflows is before a shipment reaches the port.

What Importers Should Do Next

The proposed Section 301 forced labor tariffs are still under review, but importers should not wait for a final decision to start planning.

A practical review should include confirming HTS classifications and product descriptions, mapping country of origin and supplier documentation, reviewing whether products may fall under proposed exclusions, modeling landed-cost impact at the SKU and shipment level, monitoring USTR deadlines, and coordinating with customs brokers, freight forwarders, suppliers, and internal finance teams.

The USTR announcement reflects a broader direction in trade enforcement: supply chain transparency, compliance readiness, and documentation control are becoming central to import strategy. For businesses that depend on international sourcing, the ability to respond quickly can protect margins and reduce operational disruption.

GLC helps importers move through complex trade environments with customs brokerage, freight forwarding, warehousing, and supply chain support designed for visibility and execution. Whether your company is reviewing tariff exposure, preparing import documentation, or adjusting sourcing strategy, our team can help you plan with confidence.

Review your import strategy with GLC. Contact us at [email protected] or visit our Contact Us page.