What did USTR determine on June 2, 2026?

USTR found that 60 economies failed to impose or effectively enforce a prohibition on the importation of goods produced with forced labor. Under Section 301 of the Trade Act of 1974 it proposed additional ad valorem duties structured as two tiers: 10% for lower-severity cases and 12.5% for more severe cases.

When do the duties actually take effect?

Not automatically. Written comments in the docket are due July 6, 2026; public hearings run July 7-9. USTR is expected to publish tier assignments and an effective date within roughly 60 days of the hearings, so a Q3 2026 effective date is realistic.

How does this stack with the Section 122 surcharge?

The Section 122 10% surcharge is a separate mechanism scheduled to expire July 24, 2026 unless Congress acts. Both duties would stack on top of existing Section 301 lists, Section 232 metals duties, IEEPA duties, and MFN duties. A worst-case landed cost could layer +10% Section 122, +12.5% forced-labor tier 2, and existing Section 301 for a China-origin SKU.

Should a seller file a comment before July 6?

If a specific HTS code or supplier relationship is misrepresented in the tier assignment, an on-record comment before July 6 is the only way to influence the final rule. Trade counsel can file on the company’s behalf. For most sellers, the more useful action is modelling three landed-cost scenarios (base, +10%, +12.5%) per SKU and updating pricing floors.

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USTR Section 301 forced-labor tariffs hit hearings July 7-9

Max

July 6, 2026

7 min

Summarize with AI

COO at Nova Analytics

Max leads operations at Nova Analytics, helping Amazon sellers optimize their business performance through data-driven insights and strategic automation.

Quick Summary

•USTR proposed additional 10% (tier 1) and 12.5% (tier 2) ad valorem duties across 60 economies under Section 301 forced-labor findings
•Written comment deadline is July 6, 2026; public hearings run July 7-9 in Washington
•Duty stacks on top of any existing Section 301, Section 232, IEEPA, or MFN duty already applied to the HTS code
•Could compound with the Section 122 10% surcharge expiring July 24, 2026, unless Congress extends it

Nova surfaces every Amazon fee, refund, and margin shift in your live P&L, across 23 marketplaces. Open the live P&L

What USTR proposed and what happens this week

On June 2, 2026, the U.S. Trade Representative determined under Section 301 of the Trade Act of 1974 that 60 economies failed to impose or effectively enforce a prohibition on the importation of goods produced with forced labor. USTR proposed additional duties structured as two tiers, and opened a comment docket that closes July 6, 2026 with public hearings July 7-9 (USTR docket page). The June 2 determinations are on the record (USTR press release, June 2, 2026). EY Tax News laid out the tier structure and how the comment period feeds into the final action (EY Tax News, June 3, 2026), and JDSupra summarized the seller-facing timeline (JDSupra, July 3, 2026).

The proposed structure is two-tier. Tier 1 covers countries USTR determined have the weakest enforcement of forced-labor import prohibitions and would face an additional 10% ad valorem duty. Tier 2 covers a smaller group of countries whose failures are considered more severe and would face an additional 12.5%. The proposal is on top of any existing Section 301, Section 232, IEEPA, or MFN duty already applied to the product code.

For Amazon FBA sellers this is the second big sourcing shock of the summer. The Section 122 10% surcharge is scheduled to expire July 24, 2026 unless Congress acts, and the forced-labor tier could land on top of the same containers.

Key facts

Economies in scope

Countries and customs territories under Section 301 determination

Proposed tier duties

10% - 12.5%

Additional ad valorem, stacked on top of existing duties

Comment deadline

Jul 6, 2026

Public hearings July 7-9; final action expected within 60 days

Timeline

Key Dates & Deadlines

Jun 2, 2026

USTR determinations

USTR announces Section 301 findings for 60 economies; two-tier duty proposal published.

Jun 5, 2026

Comment docket opens

USTR portal begins accepting written comments (Docket Nos. USTR-2026-0265, 0266).

Jul 6, 2026

Written comments due

Deadline for public comments in both dockets.

Jul 7-9, 2026

Public hearings

USTR hearing panel meets in Washington; virtual attendance option available.

Jul 24, 2026

Section 122 cliff

Separate 10% Section 122 surcharge expires unless Congress extends. Could compound with the forced-labor tier.

Q3 2026

Final action

USTR expected to publish tier assignments and effective date within 60 days of hearings.

Country exposure for common FBA sourcing lanes

Sourcing country	Common FBA categories	Exposure signal
Vietnam	Apparel, footwear, home textiles	In scope. Tier assignment pending.
Bangladesh	Apparel, accessories	In scope. Historic UFLPA and forced-labor commentary suggests upper tier risk.
Cambodia	Apparel, small leather goods	In scope. Upper tier risk.
Turkey	Home goods, textiles, kitchen	In scope. Lower tier likely but not confirmed.
India	Textiles, home decor, cookware	In scope. Category-specific tier risk.
China	Electronics, consumer goods	In scope, on top of the separate Section 122 surcharge and existing Section 301 lists.

Category and tier signal are directional based on the USTR determinations text. The final tier assignment is published after the July 7-9 hearings.

Seller playbook for the next 14 days

1
Map every SKU to its country of origin (COO) at HTS level
Not the country listed on the commercial invoice. The actual USTR-recognised country of origin per the HTS classification. That is the field the added duty will bind to.
2
Model landed cost under three scenarios
Base case (no forced-labor tier applied), tier 1 (+10%), tier 2 (+12.5%). Layer the Section 122 outcome on top of each. Update every SKU with a forecast landed cost per unit for Q4 planning.
3
Decide whether to file a comment before July 6
If a specific HTS classification or supplier relationship is misrepresented in the tier assignment, an on-record comment is the only path to influence the final rule. Trade counsel can file on a company's behalf.
4
Rewrite the Q4 pricing floor per SKU
A 10% to 22.5% cost shock (forced-labor tier + Section 122 if extended) on top of Amazon FBA fees moves the break-even ASP for a large slice of private-label catalogs. Set the pricing floor now, before Q4 negotiations lock.

Related coverage

Section 122 tariff expiration: FBA prep guide - the parallel July 24 cliff that could stack on the forced-labor tier.
SCOTUS IEEPA ruling and the Section 122 surcharge - the origin of the July 24 cliff.
Amazon IEEPA tariff refund lawsuit - how sellers are recouping past duties.

How Nova helps

Nova is the operating system for Amazon brands. When a tariff decision reshapes landed cost overnight, the brands that stay profitable are the ones that see cost of goods, contribution margin, and pricing headroom per SKU in one view.

Profit & Loss - track landed cost, tariffs, and FBA fees per SKU with three-scenario modelling for the forced-labor tier and Section 122.
Custom Breakdowns - group SKUs by country of origin and see contribution margin exposure across the catalog.
Winners & Losers - surface which SKUs go under water first under each tariff scenario, so re-pricing sequencing is data-driven.

Verified Sources

All information verified from official Amazon sources and trusted industry analysts as of publication date.

USTR Section 301 forced-labor tariffs hit hearings July 7-9

Quick Summary

What USTR proposed and what happens this week

Key facts

Economies in scope

Proposed tier duties

Comment deadline

Timeline

Key Dates & Deadlines

Country exposure for common FBA sourcing lanes

Seller playbook for the next 14 days

Related coverage

How Nova helps

Verified Sources

Ask Claude about your Amazon data

Ask Claude about your Amazon data

What USTR proposed and what happens this week

Key facts

Economies in scope

Proposed tier duties

Comment deadline

Timeline

Key Dates & Deadlines

Country exposure for common FBA sourcing lanes

Seller playbook for the next 14 days

Related coverage

How Nova helps

Frequently Asked Questions

What did USTR determine on June 2, 2026?

When do the duties actually take effect?

How does this stack with the Section 122 surcharge?

Should a seller file a comment before July 6?

Frequently Asked Questions

What did USTR determine on June 2, 2026?

When do the duties actually take effect?

How does this stack with the Section 122 surcharge?

Should a seller file a comment before July 6?