US expands Section 301 measures with forced labour tariffs on global imports

US imposes new forced labour tariffs on 60 trading partners as global tariff expires

Following on from the recommendations of recent report, published 2 June 2026, in respect of the Section 301 investigation on forced labour. The Trump administration has introduced new tariffs of 10% and 12.5% on imports from 60 trading partners, including the European Union and China, citing concerns over inadequate enforcement of forced labour restrictions. The measures came into effect immediately after the expiration of a temporary 10% global tariff that had been in place for 150 days under Section 122 measures. 

The announcement marks the latest attempt by the White House to revive President Donald Trump's vision of broad-based tariffs on global trade. In February, the US Supreme Court invalidated Mr Trump's previous "reciprocal" tariffs, which ranged from 10% to 50% and had been imposed under IEEPA (International Economic Emergency Powers Act) as part of efforts to reduce the US trade deficit. 

According to a Federal Register notice published late yesterday, the new duties will cover approximately 99.4% of all US imports, although several key products remain exempt. Unlike the earlier tariffs struck down by the courts, the new measures have been implemented under Section 301 of the Trade Act of 1974. This legal framework has previously withstood judicial scrutiny and provides the administration with a more durable mechanism for maintaining a baseline tariff on nearly all imported goods. 

The tariffs took effect at 5am Irish time, coinciding with the expiry of the temporary 10% global levy. Goods already in transit before the deadline will remain exempt until 28 July. 

US Trade Representative Jamieson Greer defended the move, arguing that the United States has long maintained robust restrictions on imports linked to forced labour and that trading partners should be held to similar standards, stating; 

"The United States has had a forced labour import ban for nearly a century and rigorously enforces it. It's well past time for our trading partners to do the same. Today’s action will begin to correct what is both a human rights abuse and distortive trade practice to improve the welfare of workers everywhere." 

Mr Greer has also indicated that countries which have negotiated agreements with Washington to cap US tariff rates will not see their overall tariff burdens rise above those agreed limits as a result of the new forced labour duties. 

Importantly, from an EU perspective, the tariffs will be capped at either 10% or the MFN rate, should this MFN rate be greater than 10%. This approach has been similarly applied to certain countries which have reached an agreement with the US administration with either a 10% or 12% cap applicable. 

An additional 10% tariff has been applied to imports from countries including Argentina, Bangladesh, the United Kingdom, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, and Trinidad and Tobago. 

The remaining 38 affected countries face tariffs of 12.5%. Among those countries are Vietnam and China. Vietnam recently introduced more detailed regulations aimed at preventing imports produced with forced labour, while China continues to reject US allegations concerning the treatment of Uyghur minorities in Xinjiang. 

Legal experts believe the tariffs may prove more resilient against court challenges than previous measures because they were imposed under Section 301. 

The administration also confirmed a number of significant product exemptions. These include oil and gas, fertilisers, certain food products, goods already covered by Section 232 national security tariffs, aircraft and aircraft parts, critical minerals, and qualifying products traded under the US-Mexico-Canada Agreement (USMCA).

These exemptions are particularly beneficial to Ireland as they cover several of Ireland’s most import export sectors and helps maintain competitiveness in the US market, especially for the food and agri-food industry, as Irish beef, dairy products, food ingredients and prepared food exports rely heavily on access to the US market.

The exemption for aircraft and aircraft parts is particularly relevant to Ireland given Ireland’s position as a global leasing hub, having the presence of major aviation and aerospace businesses and the countries significant transatlantic trade in aircraft components, engines and avionics. This exemption helps protect Irelands aviation ecosystem and limits disruption for the aircraft leasing and aerospace suppliers. 

Ireland’s largest goods export sector, pharmaceuticals, avoids the immediate tariff burden, protecting competitiveness and reducing risks to investment and employment. However, consideration should still be given regarding the outcome of the US Section 232 investigations into pharmaceutical imports and proposed measures. 

Furthermore, President Trump is expected to announce more tariffs under section 301. With hints of retaliation over the EU’s decision to impose a €890m (£760m) fine on Google earlier this week and a threat to impose 100% tariffs on pharma, this would hit Ireland, Germany and Belgium significantly.

Irish reaction

Irish Minister for Foreign Affairs and Trade Helen McEntee welcomed the new US tariff regime, which took effect today and replaces the previous Section 122 tariffs. She said the measures are consistent with commitments made under the Turnberry Agreement, including an all-inclusive tariff ceiling of 15%. 

"This is welcome and shows the clear value of the agreement. It also confirms that there will be no stacking of existing tariffs, which had been an area of concern for us for some of our agrifood exports, including dairy,"  

The Minister noted that Ireland, alongside its EU partners, will review the US legal notice in detail to assess its full implications. However, she said the outcome is broadly in line with expectations following discussions with US Trade Representative Jamieson Greer earlier this week. Looking ahead, McEntee indicated that efforts will continue to secure further tariff relief for strategically important sectors. 

"As we continue with the implementation of the Joint Statement, we will focus on exploring further tariff exemptions for key products and sectors for the EU and Irish economies,"  

Meanwhile, Chambers Ireland voiced concern over the latest US tariff measures, warning that they highlight the growing uncertainty facing international trade. CEO Ian Talbot noted that the US remains Ireland's largest export market and stressed the importance of stable trading conditions for Irish businesses, stating: 

"With almost half of our goods exports destined for the US, businesses need confidence that trading conditions will remain stable and predictable over the long term,"  

He argued that Ireland and the EU should respond by maintaining strong transatlantic trade ties while accelerating efforts to diversify export markets and reduce reliance on any single destination. 

"This development should provide renewed impetus for the EU to conclude and implement trade agreements with key partners. Progress on Free Trade Agreements, alongside negotiations with India, Indonesia and other growing economies, would expand market access for Irish businesses and help them build more resilient supply chains,"

Talbot also highlighted Ireland's EU Presidency as an opportunity to strengthen the Single Market by reducing barriers to trade and enabling businesses to better leverage access to a market of more than 400 million consumers.

EU, Canada and others push back against new US tariff measures

The new US tariffs prompted immediate criticism from several trading partners, with the European Union, Australia, Brazil, Norway and Canada all questioning the rationale behind the measures and signalling plans to engage with Washington on the issue. 

EU foreign policy chief Kaja Kallas described the tariffs as a surprise and challenged the US justification that they were needed to address forced labour concerns. Kallas told Reuters on the sidelines of ASEAN meetings in Manila: 

"If you compare our labour laws to the ones of the United States, I mean, we have paid vacations, we have very good labour conditions for our employees, so it's not really grounded,"  

Australia and Brazil described the measures as unjustified, while Norway said there was "no basis" for the tariffs. Canada adopted a more measured response, with Trade Minister Dominic LeBlanc emphasising continued engagement with the US: 

"We will continue engaging constructively with the United States on this matter, as well as other outstanding issues, over the coming weeks to the mutual benefit of our citizens,"  

Trade experts noted that the measures were largely in line with expectations. Kelly Ann Shaw, a former White House trade adviser, said the economic impact would likely be limited, particularly as several trading partners, including the EU, had already negotiated tariff caps. She also highlighted that an additional 471 products had been added to the exclusion list. The Trump administration rejected suggestions that the new duties were simply a replacement for the expiring global tariffs.

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