The Office of the United States Trade Representative (USTR) has initiated 60 investigations under Section 301 of the Trade Act of 1974 into foreign governments’ failures to impose and enforce bans on imports of goods produced with forced labor. The investigations cover 60 of the United States’ trading partners and may lead to new trade measures affecting all goods from those countries.
What Section 301 Investigations Are
Section 301 authorizes USTR to investigate and respond to foreign government acts, policies, and practices that are “unjustifiable,” “unreasonable,” or “discriminatory” and burden or restrict U.S. commerce.
The new investigations focus on whether each of the 60 economy’s acts, policies, and practices related to the failure to impose and enforce a ban on the importation of goods produced with forced labor are unreasonable or discriminatory and burden or restrict U.S. commerce. USTR states that, despite broad international condemnation of forced labor, many governments have not imposed or enforced effective measures to keep goods produced with forced labor out of their markets.
Economies Covered
The listed economies are: Algeria, Angola, Argentina, Australia, The Bahamas, Bahrain, Bangladesh, Brazil, Cambodia, Canada, Chile, China, Colombia, Costa Rica, Dominican Republic, Ecuador, Egypt, El Salvador, European Union, Guatemala, Guyana, Honduras, Hong Kong (China), India, Indonesia, Iraq, Israel, Japan, Jordan, Kazakhstan, Kuwait, Libya, Malaysia, Mexico, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Pakistan, Peru, Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, South Korea, Sri Lanka, Switzerland, Taiwan, Thailand, Trinidad and Tobago, Türkiye, United Arab Emirates, United Kingdom, Uruguay, Venezuela, and Vietnam.
Nicaragua: A Recent Section 301 Forced Labor–Related Action
USTR’s recent Section 301 action concerning Nicaragua illustrates the scope of potential remedies. In December 2024, USTR initiated a Section 301 investigation into Nicaragua’s acts, policies, and practices related to abuses of labor rights, abuses of human rights and fundamental freedoms, and the dismantling of the rule of law.
After a public comment process and hearing, USTR determined in October 2025 that Nicaragua’s acts, policies, and practices were unreasonable and burden or restrict U.S. commerce, and that they were actionable under Section 301. USTR then received more than 2,000 additional written comments on proposed responsive actions.
Takeaways from the Nicaragua Section 301 Action
The following are key takeaways from the Nicaragua forced‑labor‑related actions that may inform what to expect from these 60 investigations.
Countrywide coverage on all Nicaraguan goods.
No product‑specific exclusions.
Duties stack on normal tariffs, Section 232 tariffs, antidumping/countervailing duties (AD/CVD), etc.
Free trade agreement (FTA) qualifying goods under the Dominican Republic–Central America–United States Free Trade Agreement (CAFTA‑DR) exempt.
No additional restrictions on duty drawback.
Tariff rates phased in over several years.
Deadlines and Opportunities to Participate
USTR has requested consultations with all 60 governments.
Interested persons (public and stakeholders) may submit written comments and hearing requests by April 15, 2026.
USTR will hold public hearings on April 28, 2026.
Separate dockets are open for comments and for hearing requests.
Legal Advice
Our team has assisted with advising on Section 301 investigations, submitting written comments in Section 301 proceedings before the USTR, and representing clients in federal government hearings. Please reach out should you have questions about potential exposure or wish to participate in these proceedings.
Links to Documents
USTR dockets for public comments and requests to appear at the hearing on the 60 investigations