U.S. launches 60 Section 301 investigations targeting forced labour enforcement in global supply chains

First published: March 2026

 

On 12 March 2026, the Office of the U.S. Trade Representative (USTR) announced the initiation of 60 investigations under Section 301(b) of the Trade Act of 1974. The investigations will examine whether major U.S. trading partners have failed to impose and effectively enforce a prohibition on the importation of goods produced with forced labour.

The 60 economies under investigation collectively account for more than 99% of U.S. imports in 2024. They include countries central to global apparel, footwear, and consumer products supply chains, among them Bangladesh, Vietnam, India, Cambodia, Indonesia, Türkiye, Mexico, and China, as well as major economies such as the European Union, Canada, Japan, and the United Kingdom.

Ambassador Jamieson Greer stated that the investigations will determine whether foreign governments have taken sufficient steps to prohibit the importation of goods produced with forced labour and how the failure to address these practices impacts U.S. workers and businesses.

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What is a Section 301 investigation?

Section 301 of the Trade Act of 1974 authorises the U.S. Trade Representative to investigate whether acts, policies, or practices of a foreign country are unreasonable or discriminatory and burden or restrict U.S. commerce.

Under the legal framework of these investigations, USTR is examining whether the failure of trading partners to maintain and enforce forced labour import prohibitions creates an artificial cost advantage for foreign producers — thereby disadvantaging U.S. companies that must compete against goods produced under conditions of forced labour.

If affirmative determinations are made, USTR has the authority to respond with trade measures, including tariffs or other import restrictions on goods from the affected economies.

 

Sectors identified as especially vulnerable

In its Federal Register notice, USTR identified several sectors it considers particularly vulnerable to forced labour risk, including:

• Garments, textiles, thread, and yarn
• Critical minerals used in solar products and auto parts
• Fish used to produce fish oil and fish meal
• Palm fruit used to produce palm kernel oil and palm oil

The explicit inclusion of garments and textiles underscores the heightened regulatory attention being directed at apparel and textile supply chains globally.

 

Public Comment Process

USTR has opened a formal public comment process for stakeholders to provide input on the investigations.

Milestones and dates:

• • Investigation initiated: 12 March 2026
  • Public docket opens: 17 March 2026
  • Written comments and hearing requests due: 15 April 2026
  • Public hearings begin (U.S. International Trade Commission, Washington, DC): 5 May 2026
  • Hearings may continue through: 8 May 2026
  • Post-hearing rebuttal comments due: 7 days after close of hearings

Comments and requests to testify can be submitted through the official USTR electronic portal at https://comments.ustr.gov/s/ under docket number USTR–2026–0133.

This process allows companies, industry associations, and other stakeholders to provide perspectives on forced labour enforcement practices, supply chain realities, and the potential impact of trade measures across the investigated economies.

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What this signals for global supply chains

While the outcome of these investigations remains uncertain, several dimensions of this action are worth noting:

• • • Breadth of scope. Unlike enforcement actions that target a single country or region, these investigations span 60 economies simultaneously. This represents a significant expansion of how forced labour compliance is being addressed within U.S. trade policy.
    • Sector-specific focus. USTR’s explicit identification of garments, textiles, thread, and yarn as high-risk sectors signals that apparel and textile supply chains will continue to face elevated scrutiny, not only at the U.S. border, but through trade policy mechanisms that reach into sourcing countries themselves.
    • Shifting the compliance burden globally. The core theory of these investigations is that foreign governments, not just importers, bear responsibility for preventing forced-labour goods from entering commerce. If trade measures result, they could affect imports from any of the 60 investigated economies, including countries that are current alternatives in diversified sourcing strategies.
    • Evidence and enforcement convergence. Regulators are increasingly focused not only on documentation, but on whether companies and governments can demonstrate credible, verifiable evidence supporting their supply chain and origin claims. The standard is shifting from procedural compliance to substantive proof.

 

What companies should consider

Organisations sourcing materials or finished goods internationally, particularly in the apparel, footwear, textile, and consumer products sectors, should evaluate their readiness in several areas:

• • • Origin verification. Can your organisation substantiate the origin of raw materials and intermediate goods with verifiable evidence, not just supplier declarations?
    • Multi-tier traceability. Do your due diligence frameworks extend beyond direct (Tier 1) suppliers to cover upstream tiers where forced labour risk is most acute?
    • Sourcing diversification risk. If trade measures are imposed on specific economies, how would your current sourcing strategy be affected? Are alternative sourcing countries also among the 60 under investigation?
    • Documentation and evidentiary standards. Is your supply chain documentation robust enough to withstand regulatory scrutiny that demands proof of claims, including material origin, labour compliance, and chain of custody?

As regulatory expectations continue to evolve, the ability to provide verifiable proof of material origin and supply chain integrity is becoming increasingly important, and increasingly expected by regulators, customs authorities, and trading partners alike.

 

For questions about how these developments may affect your testing, compliance, or supply chain verification requirements, please contact us.

 

Sources

• USTR Press release: https://ustr.gov/about/policy-offices/press-office/press-releases/2026/march/ustr-initiates-60-section-301-investigations-relating-failures-take-action-forced-labor
• Federal Register Notice: https://www.govinfo.gov/content/pkg/FR-2026-03-17/pdf/2026-05214.pdf

 

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