USTR Forced Labor Section 301 Proposal: What China Importers Should Check in 2026

USTR announced findings and proposed Section 301 actions on June 2, 2026 after investigations into foreign practices related to forced labor. The June 5, 2026 Federal Register notice sets a July 6, 2026 comment deadline and a July 7, 2026 public hearing. China and Hong Kong are included among the investigated economies listed in the notice.

The notice proposes additional duties on products of investigated economies, except products excluded in Annex A. It describes a 10% proposed rate for economies with a forced-labor import prohibition, certain commitments, or a partial regime, and a 12.5% proposed rate for other economies. Importers should have qualified advisers apply the notice, Annex A, HTS details, and any later USTR or CBP instructions to their own products.

The proposal is not a final duty schedule. That distinction matters. A sourcing team should not tell customers that a new duty is already due, but it should treat the proposal as a reason to clean up supplier, product, origin, invoice, and forced-labor evidence while goods are still in China and before the importer has to make a policy, customs, or release decision.

Section 301 actions can move through investigation findings, public comments, hearings, modified action lists, implementation instructions, and customs guidance. The June 2026 notice is a proposed action stage. Importers, brokers, and trade counsel should own the legal and tariff interpretation.

For China sourcing, the immediate practical work is narrower: know which products are exposed, which suppliers and production sites are involved, which paperwork will be used, and which gaps should block a deposit, balance payment, or pickup until the U.S. owner reviews them.

A clean sales contact does not prove who made the goods. Buyers should compare the quoted supplier, Chinese legal name, invoice issuer, exporter, bank beneficiary, factory, subcontractor, processor, packer, pickup location, and upstream material supplier when those records are available.

This is especially important when forced-labor questions and tariff exposure overlap. A supplier may be able to answer simple quote questions but still fail to explain production site, material origin, subcontracting, or upstream records. Those gaps should be visible before the buyer loses leverage.

The importer or broker cannot make clean decisions from mismatched product records. SKU list, product photos, model labels, material notes, accessory sets, invoice wording, packing list, carton labels, and HTS or tariff instructions should point to the same item and lot.

Origin evidence should also be treated carefully. A shipment routed through another place, an export agent, or a Hong Kong sales office does not automatically change country of origin. The importer should decide origin and tariff treatment, but the sourcing file should keep production and routing facts separate.

A generic supplier declaration is weak if it cannot be tied to the actual product, factory, material, or order lot. For flagged products, the file should show supplier-chain names, production location, material notes, upstream records when available, high-priority sector exposure, and any U.S. team instructions about UFLPA, WROs, CAATSA, or other forced-labor controls.

The goal is not to certify that forced labor is absent. The goal is to make the evidence and gaps explicit so the responsible importer can decide whether to comment, proceed, require correction, ask for specialist review, split goods, delay pickup, or cancel before further payment.