On March 12^th, the Office of the United States Trade Representative (USTR) initiated investigations under Section 301(b) of the Trade Act of 1974 of 60 countries for potential forced labor violations resulting in unfair competition for US companies selling abroad. According to U.S. Trade Representative Jameison Greer, the investigations will examine whether these countries have failed to take adequate measures to prevent goods produced with forced labor from entering global supply chains in a manner that burdens or restricts U.S. commerce and places U.S. exporters at a competitive disadvantage abroad.

The full list of all 60 countries covered by the investigation can be found at the USTR announcement and ranges from China to Switzerland, including several of the United States’ largest trading partners. If USTR determines that the acts, policies, or practices under review are unreasonable or discriminatory and burden U.S. Commerce, the agency may impose several remedies including tariffs, import restrictions, or the suspension of trade agreements.

Public hearings on the matter are scheduled to take place between April 28^th and May 1^st, 2026, with written comments due by April 15^th, 2026. For countries without a trade agreement with the United States, a determination is generally expected within 12 months after the investigation begins.

USTR has previously investigated forced labor concerns in the context of Nicaragua. In 2024, the Biden administration initiated the first-ever Section 301 investigation targeting labor rights, human rights and rule of law violations. On October 20, 2025, USTR determined that Nicaragua’s acts, policies and practices were unreasonable and burdened U.S. commerce, and structured a remedy phased in over two years on all imported Nicaraguan goods, rising to 10 percent on January 1, 2027 and 15 percent on January 1, 2028.  This gives a concrete template for what may follow for other economies.

Companies with international supply chains or export operations involving the affected jurisdictions should monitor the investigations closely, as any resulting trade measures could impact sourcing strategies and compliance obligations.  In the policy context, these new Section 301 investigations represent a strategic shift to use Section 301’s forced labor authority as the legal backbone for a broad global tariff regime, after IEEPA-based tariffs were struck down.  Companies importing from any of the 60 covered economies face potential new tariffs and must urgently audit forced labor exposure across their supply chains.
Targeting close allies like the EU, UK, Canada, Japan, and Australia on forced labor grounds — economies with their own robust enforcement laws — is likely to generate significant diplomatic friction.

For additional information regarding submissions of comments or participation in the hearing, please feel free to reach out to Crowell & Moring for assistance.