The proposed Section 301 action turns forced-labour enforcement into a wider tariff-risk issue for apparel, textile and fibre supply chains.
The United States Trade Representative has proposed additional duties on imports from 60 economies after finding that their forced-labour import controls are either absent or inadequately enforced. The proposal, issued under Section 301 of the Trade Act of 1974, could add a new tariff layer to sourcing from many of the world’s largest apparel and textile suppliers.
A broad tariff weapon
USTR proposes additional duties on all products from the investigated economies, subject to exceptions in its Federal Register notice. Economies that already impose, partially impose, or have committed through reciprocal trade agreements to impose forced-labour import prohibitions would face a proposed 10% additional duty. All other economies would face a proposed 12.5% duty.
The list includes several major textile and apparel sourcing economies, including Bangladesh, Cambodia, China, India, Indonesia, Pakistan, Sri Lanka, Türkiye and Vietnam. USTR said 54 economies had failed to impose and effectively enforce forced-labour import bans, while six — Canada, Ecuador, the EU, Indonesia, Mexico and Pakistan — had failed to effectively enforce such prohibitions.
Textile mechanism offers limited relief
For the textile sector, the most important detail is USTR’s proposed textile mechanism. This would allow a certain volume of apparel and textile imports from selected economies to enter the United States at a reduced Section 301 tariff rate. The mechanism could become commercially important for sourcing countries heavily dependent on the US apparel market, but its scope, country eligibility and quota volumes still require clarification.
The investigation is rooted in USTR’s argument that forced labour creates artificial cost advantages and distorts competition against firms that do not use forced-labour inputs. Earlier USTR materials specifically identified cotton used in garments, textiles, thread and yarn among inputs that can transmit forced-labour risk downstream.
Compliance becomes price risk
The immediate timetable is tight. Requests to appear at hearings are due by June 22, 2026, written comments by July 6, and hearings are scheduled for July 7. USTR said it had already received testimony from nearly 60 witnesses and about 500 comments and rebuttal comments during the investigation process.
For textile exporters, the issue is no longer only social compliance. It is becoming a direct tariff, costing and market-access risk. The next signal to watch is whether the textile mechanism provides meaningful relief — or becomes a narrow carve-out that leaves most apparel and textile shipments exposed to higher US landed costs.
