USTR Issues Forced Labor Findings Under Section 301 Investigation
Importers and global manufacturers must reassess supply chains now that USTR has issued forced labor findings under Section 301, signaling potential new tariff exposure.
The Office of the U.S. Trade Representative has concluded findings in a Section 301 investigation tied to alleged use of forced labor in foreign production, a step that historically precedes tariff action or import restrictions targeting specific sectors or countries. For in-house counsel at companies sourcing from regions implicated in the probe, the findings raise the prospect of new duties, customs enforcement, and due-diligence obligations on suppliers. Recommended next steps include reviewing supplier audit records, mapping high-risk inputs, preparing for possible exclusion processes, and updating customs compliance programs to address forced-labor screening under U.S. law.