New Section 301 forced labor import duties became effective today, July 24, 2026, creating immediate tariff, classification, and entry-filing considerations for U.S. importers. The action applies to imports from 60 economies and generally imposes an additional duty of 10% or 12.5%, subject to product, country, trade agreement, and in-transit exemptions.
U.S. Customs and Border Protection issued CBP’s CSMS guidance on July 23 with filing instructions for importers, customs brokers, and entry filers. The duties apply to covered merchandise entered for consumption, or withdrawn from warehouse for consumption, at or after 12:01 a.m. Eastern time on July 24, 2026.
For importers with cargo already moving, entries scheduled this week, or products sourced from multiple countries, the immediate priority is determining whether the new Section 301 forced labor import duties apply before the entry summary is transmitted.
What Changed Under the Final Section 301 Action?
The Office of the U.S. Trade Representative finalized the action after investigating whether 60 economies failed to impose and effectively enforce prohibitions on imports made with forced labor. According to USTR’s final Section 301 action, the tariff structure distinguishes between economies that have adopted, committed to adopt, or partially implemented forced-labor import restrictions and those that have not.
A 10% additional tariff generally applies to specified economies that have taken qualifying steps. These include Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, and the United Kingdom.
A 12.5% additional tariff generally applies to the other covered economies, including Brazil, China, Colombia, Israel, Thailand, Vietnam, and others identified in CBP’s guidance.
The European Union, Japan, South Korea, Switzerland, and Taiwan have special duty calculations. Depending on a product’s existing column one duty rate, the combined regular duty and Section 301 rate may be limited to 10% or 12.5%, rather than calculated as a straightforward additional tariff.
Because treatment varies by economy, product, and existing duty rate, importers should avoid applying a single percentage across their entire product catalog.
Which Imports May Be Exempt?
The new tariffs are broad, but they do not apply uniformly to every product from every covered economy. Importers should review the specific Chapter 99 provision, the Chapter 1–97 HTS classification, country of origin, and any potentially applicable exemption before calculating landed cost.
General exemptions include certain civil aircraft and components, articles for pharmaceutical applications, humanitarian donations, informational materials, and specified products already covered by Section 232 measures. The Section 232-related category includes certain aluminum, steel, copper, vehicles, vehicle parts, wood products, and semiconductor articles.
The final action also contains product-specific and economy-specific exclusions. Because the exemption list is extensive, importers should not rely only on a general product description or supplier statement. The exact HTSUS classification and relevant U.S. note must be reviewed.
Canada and Mexico receive especially important treatment. Products of Canada or Mexico entered free of duty under the United States-Mexico-Canada Agreement are exempt from the new additional duties under the applicable Chapter 99 headings. This makes origin qualification, USMCA data, and supporting entry documentation even more important for North American trade.
GLC previously outlined the proposed measure in our earlier overview of Section 301 forced labor tariffs. Importers should now replace preliminary cost scenarios with product-level calculations based on the final rates and exemptions.
Is There an In-Transit Exception?
Yes, but the window is narrow.
Covered merchandise may qualify for the in-transit exception when it was loaded onto a vessel at the port of loading and was already in transit on the final mode of transportation before 12:01 a.m. Eastern time on July 24, 2026.
The goods must also be entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. Eastern time on July 28, 2026.
Importers seeking this treatment should maintain documentation supporting the loading date, routing, final mode of transit, arrival timeline, and entry date. Cargo that misses the July 28 deadline may become subject to the new duty even when it departed before the effective date.
What Are the Entry-Filing Requirements?
CBP issued a specific HTSUS reporting sequence for entries involving Chapter 98 or Chapter 99 provisions. When applicable, filers should report Chapter 98 first, followed by the Chapter 99 numbers associated with additional duties.
For entries involving multiple trade remedies, CBP instructs filers to report Section 301 before Section 122, Section 232, and Section 201 provisions. The underlying Chapter 1–97 commodity classification is reported later in the sequence, and the entered value generally remains associated with that commodity classification unless Chapter 98 requires different treatment.
Products subject to the action and admitted into a U.S. foreign-trade zone generally must be admitted in privileged foreign status unless they are eligible for domestic status. Importers using foreign-trade zones should review their admission procedures immediately to reduce the risk of duty-treatment errors.
The new Section 301 forced labor import duties do not replace antidumping, countervailing, or other applicable duties, fees, taxes, and charges. Companies therefore need a complete duty-stack review rather than simply adding 10% or 12.5% to their existing landed cost.
Five Actions Importers Should Take Now
1. Identify affected shipments
Review open purchase orders, in-transit shipments, warehouse withdrawals, and upcoming entries involving any of the 60 covered economies.
2. Validate the country of origin
The country of export, supplier location, and country of origin may not be the same. Importers should verify origin using complete production and sourcing information.
3. Review HTS classifications
Compare product classifications against the new Chapter 99 headings and exemption lists. Product descriptions alone may not be sufficient to establish eligibility for an exclusion.
4. Confirm special tariff treatment
Determine whether USMCA, another country-specific provision, Chapter 98 treatment, a product exemption, or the limited in-transit exception may apply. Supporting records should be organized before the entry is filed.
5. Update landed-cost calculations
Review customs bonds, pricing assumptions, sourcing models, cash-flow projections, and customer communications. Even a 10% additional duty can materially affect margins, inventory planning, and purchasing decisions.
Why Supplier and Product Data Matter
The new measure reinforces the importance of maintaining accurate product descriptions, material composition, manufacturing location, tariff classification, valuation data, and supporting origin documentation.
A product may be exported from one economy but originate in another. It may also contain components subject to separate trade remedies or qualify for treatment that depends on the manufacturing process.
Importers should coordinate with suppliers before cargo departs rather than waiting until entry preparation begins. Missing or inconsistent data can delay classification review, exemption analysis, entry transmission, and cargo release.
Procurement, finance, compliance, and logistics teams should also work from the same tariff assumptions. When one department applies the new duty and another continues using an older cost model, purchasing and pricing decisions may be based on inaccurate landed costs.
How GLC Can Support Importers
The immediate effective date leaves little room for delayed review. Importers need accurate product data, coordinated entry instructions, and clear communication among suppliers, purchasing teams, customs brokers, finance departments, and transportation providers.
The GLC customs brokerage team can help importers organize shipment information, review entry requirements, coordinate classification support and Chapter 99 reporting, assess potential exemptions, and provide visibility through cargo release.
Companies should review each shipment individually because tariff treatment depends on the product, country of origin, entry timing, applicable trade programs, and supporting documentation.