Summary:
On 23 July, the Office of the United States Trade Representative announced tariffs on imports from 60 economies, following an investigation that found these trading partners had failed to impose or effectively enforce a ban on goods produced with forced labor. The measures apply in two tiers: a 10 percent rate for economies that already maintain such a prohibition, have committed to one, or operate a partial regime, and a 12.5 percent rate for all remaining investigated economies. Ambassador Jamieson Greer framed the decision as long overdue, arguing that decades of moral pressure had failed to remove forced labor from global supply chains and that it was "well past time" for trading partners to match the ban the United States has enforced for nearly a century. The investigation identified cotton and textiles, polysilicon used in solar supply chains, and certain critical minerals as goods repeatedly linked to forced labor. Several Western allies pushed back. New Zealand called the tariffs extremely disappointing and questioned the evidence, Australia described them as unjustified, Canada rejected the rationale, and the European Commission said the duties were unjustified while indicating it may accept them below a previously discussed ceiling. By tying tariff rates to the presence or absence of a forced-labor import ban, the United States has created a durable legal pathway that functions as a continuing condition for more favourable treatment rather than a one-off penalty.
Detailed Report
1. New Tariffs Announced
The Office of the United States Trade Representative (USTR) announced on 23 July that tariffs would be applied to imports from 60 economies. The decision rests on a formal finding that these economies failed to impose and effectively enforce a prohibition on the importation of goods produced with forced labor. Investigations into the matter began in March and included public hearings as well as more than 2,100 written submissions.
Ambassador Jamieson Greer framed the decision as long overdue. He noted that the United States has maintained its own ban on forced-labor imports for nearly a century and continues to enforce it. Decades of moral pressure, he argued, had not removed the practice from global supply chains. "It's well past time for our trading partners to do the same," Greer said. The tariffs, he added, would begin to correct what he described as both a human rights abuse and a distortive trade practice.
The tariffs are structured in two tiers. A 10 percent tariff applies to economies that already maintain a forced-labor import prohibition, that have committed to introduce one under reciprocal trade agreements, or that operate a partial regime able to block certain forced-labor goods. Canada, Mexico, the United Kingdom, India and Indonesia fall into this group. Certain products from the European Union, Japan, South Korea, Switzerland and Taiwan face rates of 10 percent or 12.5 percent after most-favored-nation duties are accounted for. A 12.5 percent tariff applies to all remaining investigated economies that have neither imposed a forced-labor import prohibition nor committed to one. This higher rate covers Australia, New Zealand, China, Brazil and the other economies not listed in the lower tier. A range of product categories is exempt.
2. USTR's Criteria for Forced-Labor Import Prohibitions
The United States is requiring its trading partners to put in place and enforce a legal ban on the importation of goods produced wholly or in part with forced labor. USTR states that the prohibition must be unequivocal. Transparency rules, due-diligence requirements or voluntary disclosure schemes are not considered sufficient.
USTR identifies several elements as important for effective enforcement:
• A statutory definition of forced labor grounded in international law
• A designated enforcement authority
• A public entity list
• A rebuttable presumption where forced labor is established for particular goods or regions
• Clear evidentiary standards, ideally based on "reasonable cause"
• A remediation requirement
• An accessible reporting mechanism
• Transparency and public disclosure
The investigation found that 54 of the 60 economies had failed to impose any legal prohibition. Six others — Canada, Ecuador, the European Union, Indonesia, Mexico and Pakistan — maintained prohibitions on paper but did not enforce them effectively. In the final determination, several of these economies were assigned the lower 10 percent rate after making commitments or operating partial regimes.
3. High-Risk Goods Identified in the Investigation
In the report that accompanied its determination, USTR identified cotton and textiles, polysilicon used in solar supply chains, and certain critical minerals as products repeatedly linked to forced labor. The report states that nearly all of the investigated economies imported cotton from China in recent years, and that 92.8 percent of China's cotton originates in the Xinjiang region. Polysilicon production in Xinjiang is described as carrying a similarly high risk, with downstream solar products then entering global supply chains. Broader categories of goods appearing on the US Department of Labor's list of products produced by forced labor, including seafood, cocoa, coffee and selected agricultural commodities, are also referenced. These findings form the basis for the United States' demand that other economies adopt and enforce their own import bans.
4. Responses from Western Allies
New Zealand Prime Minister Christopher Luxon called the tariffs extremely disappointing. "The US investigation did not provide meaningful evidence to support claims in relation to forced labour," he said. "Tariffs are not the way — they drive up costs and uncertainty for businesses." He pointed to New Zealand's efforts to secure new trade agreements as a means of giving exporters greater certainty.
Australian Trade Minister Don Farrell described the tariffs as unjustified and inconsistent with the free-trade agreement between Australia and the United States. "Australia's measures to combat forced labour and modern slavery are among the strongest in the world and we are recognised globally, including in the US, for our leadership," Farrell said. The government said it would continue pressing for their removal.
Canada, which faces the lower 10 percent rate, has rejected the US rationale. Ottawa maintains that it already operates a forced-labor import prohibition and has introduced legislation to strengthen enforcement. Prime Minister Mark Carney has characterised successive US tariff actions as a sovereignty concern and stressed the need for greater economic resilience and trade diversification.
The European Commission has called the duties unjustified but indicated it is prepared to accept them if they remain below the 15 percent ceiling previously discussed with the United States.
5. Tariffs as a Durable Legal Pathway
The new measures restore a broad layer of duties on imports into the United States after the Supreme Court struck down earlier global tariffs that had been imposed under emergency powers. A separate, temporary tariff authority under the Trade Act was also nearing the end of its 150-day legal limit. By linking the applicable rate to the presence or absence of a forced-labor import prohibition, the United States has created both an immediate penalty and a continuing incentive: economies that introduce and enforce such bans remain eligible for the lower 10 percent tier. The structure therefore functions as a lasting condition for more favourable tariff treatment rather than a one-off measure.
Conclusion
The tariffs announced on 23 July now apply across all 60 economies named in the investigation, with the rate each faces set by whether it maintains and enforces a ban on forced-labor imports. The USTR has set out the standards it expects trading partners to meet, identified the goods it regards as highest-risk, and left the lower tier open to those that adopt an enforceable prohibition. Several allies have objected and pledged to keep pressing their case, but for now the measures stand, and the path to more favourable treatment runs through the ban the United States has asked its partners to put in place.