Section 301 forced-labor tariffs take effect
Among origins covered here, China, Vietnam, Thailand, Türkiye and the Philippines face an additional 12.5%; Bangladesh, India, Cambodia, Pakistan, Indonesia and Sri Lanka face 10%. This is an additional duty layer; consult the notice for product exemptions and transit provisions.
Our read
China and Vietnam both pay the new 12.5% layer, but their totals differ: the same knit cotton T-shirt is 36.5% from China, 29% from Vietnam and 26.5% from Bangladesh. If you are thinking of switching origin, compare purchase price, freight and every duty layer, not just the new one.
Key dates
- Published
- Additional duty applies from 12:01 a.m. Eastern time, based on entry for consumption or withdrawal from warehouse for consumption
- Qualifying goods loaded and on their final transit before July 24 also need entry or warehouse withdrawal before 12:01 a.m. Eastern time on this date for the transit exception
- We checked the official text
Who is affected
- Sellers importing ordinary apparel from investigated economies such as China, Vietnam and Thailand. This duty follows origin and product coverage; it is not limited to individual shipments found to contain forced labor.
- Sellers comparing origins need the full duty stack. China also has the earlier China-specific Section 301 duty, so comparing only the new 10% and 12.5% rates is incomplete.
- Listed exempt products and goods meeting every transit condition are outside this additional duty; other duties and import requirements still need separate review.
Run the numbers
| Origin | General + earlier China Section 301 + new Section 301 | Total rate | Duty |
|---|---|---|---|
| China | 16.5% + 7.5% + 12.5% | 36.5% | $7.30 |
| Vietnam | 16.5% + 0% + 12.5% | 29% | $5.80 |
| Bangladesh | 16.5% + 0% + 10% | 26.5% | $5.30 |
What to do
- Check the new duty using the manufacturing origin and US tariff classification, not the transit country.
- Separate general duty, the earlier China Section 301 duty and the new Section 301 duty before comparing purchase, freight and import costs across origins.
- For past entries, check both transit conditions: loading and final transit before July 24, plus qualifying entry or warehouse withdrawal before July 28.
What the official text says
Notwithstanding U.S. note 1 to this subchapter, all products that are subject to the additional ad valorem rates of duty imposed by these headings shall also be subject to the general rates of duty imposed under subheadings in chapters 1 to 97 of the tariff schedule.
Except as provided in subdivisions (b) through (k) of this note, all products that are subject to the additional ad valorem rates of duty imposed by headings 9903.05.20-9903.05.84 shall also be subject to any additional duty provided for in this subchapter or in subchapter IV of chapter 99.
Sources
- USTR Takes Action in Forced Labor Section 301 Investigations
- Notice of Actions in Section 301 Investigations of Acts, Policies, and Practices of Various Economies Related to the Failure of Each Economy To Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced With Forced Labor