Washington Wire: USTR Finalizes New Section 301 Forced Labor Tariffs

In This Issue:
• USTR Finalizes New Section 301 Forced Labor Tariffs
• Senate Committee Advances College Transparency Act
• EPA Extends PCE and Carbon Tetrachloride Compliance Dates
• CBP Adds Copper Smelt-and-Cast Reporting Requirements
• FTC Warning Puts “Made in USA” Claims Back in Focus

USTR Finalizes New Section 301 Forced Labor Tariffs

The Office of the U.S. Trade Representative (USTR) announced final action July 23 in Section 301 investigations concerning forced labor import practices in 60 economies. The action imposes new duties of 10 to 12.5 percent on covered imports entered for consumption, or withdrawn from warehouse for consumption, beginning at 12:01 a.m. Eastern time on July 24, 2026.

The final action has three rate structures. Seventeen economies, including Canada, Mexico, India, Indonesia, Malaysia and the United Kingdom, face an additional 10 percent tariff. For goods from the European Union and Taiwan, the new Section 301 tariffs incorporate the most-favored-nation (MFN) general duty rate to combine for a maximum rate of 10 percent. The comparable combined ceiling is 12.5 percent for Japan, South Korea and Switzerland inclusive of the MFN general duty rate. Covered goods from the remaining investigated economies, including China, Brazil and Vietnam, generally face an additional 12.5 percent duty.

The action excludes USMCA-compliant goods and products covered by specified Section 232 measures, including certain steel, aluminum, copper, vehicle, vehicle-part and semiconductor articles. Additional exclusions cover designated tariff classifications, supply-sensitive goods, informational materials, donations and accompanied baggage. USTR also established a tariff-rate quota for qualifying textile, apparel and cotton products from selected countries. Goods already on the water before the effective time were exempt only if entered before July 28.

Unless otherwise specified, the forced labor duties are added to ordinary customs duties and can stack with existing China Section 301 tariffs. It is unclear at this time if the pending Section 301 tariffs on manufacturing excess capacity covering 16 economies will stack on top of the force labor tariffs for each covered country or only in some circumstances such as imports from China.

Senate Committee Advances College Transparency Act

The Senate Health, Education, Labor and Pensions Committee approved the College Transparency Act by a 21–1 vote on July 30. The bipartisan legislation would establish a federal student-level data network intended to provide more complete information about college enrollment, completion, costs and post-college earnings.

Current federal data do not provide a complete picture of outcomes for all students or allow consistent comparisons across individual programs of study. The proposed system would connect information held by federal agencies and educational institutions while requiring public reporting of outcomes by institution and academic program. Supporters argue that the resulting data would allow students to compare educational pathways based on completion rates, debt and earnings.

One Voice has long supported previous measures similar to this legislation, which could provide better information about whether community-college, technical and credential programs are preparing students for available careers. Program-level employment and earnings data could also help policymakers, employers and educational institutions identify where training investments are producing results and where curricula may need to be adjusted to match regional workforce demand.

Committee approval sends the measure to the full Senate, and pending action in the U.S. House may be incorporated into broader year-end legislation.

EPA Extends PCE and Carbon Tetrachloride Compliance Dates

The Environmental Protection Agency (EPA) has finalized extensions of several compliance dates under the Toxic Substances Control Act rules for perchloroethylene (PCE) and carbon tetrachloride (CTC). The final rule became effective July 28 and gives affected non-federal facilities additional time to implement portions of the workplace chemical-protection programs.

For PCE, initial workplace exposure monitoring generally must now be completed by June 21, 2027. Deadlines for meeting the existing chemical exposure limit, establishing regulated areas and implementing required respiratory protection measures generally move to September 20, 2027. Affected non-federal facilities generally have until December 20, 2027, to establish and implement exposure-control plans. The deadline for PCE dermal protections was not extended.

EPA also extended certain CTC deadlines for non-federal owners and operators. Initial monitoring is generally due June 21, 2027, while the exposure-limit, regulated-area, workplace-training and respiratory-protection provisions generally take effect September 20, 2027. Neither extension changes the chemicals’ underlying exposure limits or removes the workplace protection requirements.

CBP Adds Copper Smelt-and-Cast Reporting Requirements

U.S. Customs and Border Protection (CBP) has implemented new country-of-smelt and country-of-cast reporting requirements for certain insulated copper wire and cable products. Beginning July 30, importers entering covered products insulated electric conductors, for a voltage not exceeding 1,000 V, fitted with connectors (HTS 8544.42.10; 8544.42.20; 8544.42.90); other insulated electric conductors, for a voltage not exceeding 1,000 V (HTS 8544.49.10) must provide the required information through the Automated Commercial Environment entry-summary process.

Importers must report the primary country of smelt, the country of cast and, when applicable, the secondary country of smelt. If the information is unavailable, CBP is temporarily allowing importers to report “OTH,” or other. That accommodation does not eliminate the reporting obligation and may be revisited as the government develops its copper traceability program.

The change is a customs-reporting requirement rather than a new tariff. Nevertheless, it expands the supply-chain documentation needed for products subject to the copper Section 232 framework and may require importers to obtain information not previously included in ordinary supplier records.

The immediate requirements apply only to the listed wire and cable classifications, but they may affect manufacturers importing machinery, controls, wiring systems or assemblies containing covered products.

FTC Warning Puts “Made in USA” Claims Back in Focus

The Federal Trade Commission (FTC) sent warning letters July 6 to seven companies that appeared to make questionable “Made in USA” claims and to one company over a “Made in Texas” claim. The products included industrial laser machinery and coordinate measuring machines, making the action directly relevant to manufacturing equipment suppliers. Warning letters are not final findings of a violation, but they direct recipients to review and correct potentially unsupported representations.

An unqualified “Made in USA” claim generally means that a product is assembled in the United States, all significant processing occurs domestically and all, or virtually all ingredients or components are made and sourced in the United States. The standard applies to labels, websites, catalogs, advertising and other materials that expressly or implicitly communicate U.S. origin.

Substantial domestic processing does not automatically support an unqualified claim when meaningful imported content, such as an imported blank, casting, forging or subassembly, is used. Such products may require a qualified claim describing the extent of U.S. production.

The letters follow an executive order prioritizing enforcement against unlawful domestic-origin claims. The FTC’s warning letters do not establish that every recipient violated the law, but they signal continued scrutiny of domestic-origin representations.

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