Home  ›  Blog

The Forced Labor Tariff Is Here. Check the Exemptions First

By Andrew Miller

Three weeks ago, we mentioned that the Office of the U.S. Trade Representative (USTR) was considering enforcing tariffs on goods from 60 countries.

At the time, the public comment window on the case had just closed. The hearing hadn’t happened yet. After thousands of comments across two rounds of hearings, a decision was made last Thursday.

Tariffs proposed under Section 301 of the Trade Act of 1974 took effect July 24.

The reasoning is mainly an ethical one. America has banned imported goods made with forced labor for nearly a century. However, other countries across the world lack such laws.

Some of them are America’s largest trading partners.

So, the USTR spent months checking whether 60 of these countries have and enforce a similar ban of their own on goods entering their countries. None of them currently meet that bar. All 60 face new tariffs on their exports to the U.S.

The rates vary by country, but the baseline tariff rate is 10%. Some countries pay more, up to 12.5%, depending on where USTR landed on their enforcement record. The full list, covering major trading partners including the UK, the EU, India, China, and Japan, is on USTR’s site.

Several categories of goods are exempt entirely, though.

Goods from Canada and Mexico that already qualify duty-free under USMCA are untouched. So are textiles and apparel from Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, or Nicaragua that already move duty-free under CAFTA-DR.

Products already covered by a separate set of Section 232 tariffs don’t get taxed twice under this one. There’s also a carve-out for raw materials the U.S. can’t source domestically, plus goods whose tariffing would cause disruption well beyond the intended target.

There’s a short grace period, too. Goods already loaded onto a vessel before last Friday’s deadline are exempt entirely, as long as they clear U.S. customs by July 28. CBP’s guidance breaks all of this down by country and product.

If you import from any of the 60 countries on the list, the headline rate isn’t necessarily what you’ll pay. Check whether you qualify for an exemption before you assume it is.

P.S. New tariffs, new costs, tighter margins. If you’re feeling the squeeze and need financing to bridge it, let’s talk.