US Trade Representative begins Section 301 forced labour investigations into 60 countries

The investigations aim to determine "whether acts, policies and practices of each of these economies related to the failure to impose and effectively enforce a ban on the importation of goods produced with forced labour are unreasonable or discriminatory and burden or restrict US commerce".

“Despite the international consensus against forced labour, governments have failed to impose and effectively enforce measures banning goods produced with forced labour from entering their markets," said US trade representative Jamieson Greer. "For too long, American workers and firms have been forced to compete against foreign producers who may have an artificial cost advantage gained from the scourge of forced labour."

Compliance pressure on multi-tier automotive supply chains

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The USTR's probe into forced labour practices underscores the growing expectation for end-to-end supply chain transparency under evolving forced labour compliance regimes. The deeply tiered structure of the automotive industry, combined with its global sourcing and distribution footprint, makes it particularly exposed to these requirements. For automotive logistics, compliance is no longer confined to procurement oversight – it has become a network-wide traceability function.

Importers are increasingly expected to demonstrate multi-tier supplier mapping, country-of-origin verification, documented risk assessments and evidence of corrective action procedures. This elevates trade compliance into a cross-functional priority, requiring accurate data visibility across every tier of the supply chain.

The enforcement of the Uyghur Forced Labor Prevention Act (UFLPA), enacted into US law in December 2021 to ensure that goods made with forced labour in the Xinjiang Uyghur Autonomous Region of China do not enter the US market, provides a clear example of how forced labour policy can translate into operational disruption.

Read more: Six OEMs join AIAG in requiring additional forced labour due diligence from suppliers

For the first time, six leading carmakers with the Automotive Industry Action Group (AIAG) have come together in a joint letter to require suppliers to complete new forced labour due diligence.

Under this framework, importers bear the burden of proving compliance, and shipments may be detained at US ports if sufficient traceability documentation is not provided – shifting compliance responsibility across multiple tiers of the automotive supply chain. This highlights how trade compliance has evolved beyond a procurement concern to become a cross-functional operational discipline embedded throughout the supply chain.

Given the complexity of vehicle manufacturing – with vehicles made up of components from around the world, often themselves comprised of multiple subcomponents from different countries – supplier transparency platforms, digital traceability tools, and well-resourced customs teams are becoming critical operational capabilities in 2026.

Non-compliance risks can be significant, ranging from contract termination at the supplier level to legal and regulatory exposure for OEMs if forced labour concerns are identified further upstream.

Potential for additional tariffs

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These investigations have been initiated under Section 301 of the Trade Act of 1974, through which the USTR is authorised by US Congress to investigate and take action to enforce US rights under trade agreements and respond to certain foreign trade practices.

Under Section 301, the USTR is authorised to: impose tariffs and import restrictions; withdraw or suspend trade agreement concessions; and enter into a binding agreement with a foreign government to either cease the conduct in question or compensate the US. There is no limit to the rate of Section 301 tariffs, with the law stating that the level of retaliatory action should "affect goods or services of the foreign country in an amount that is equivalent in value to the burden or restriction being imposed by that country on" US commerce.

The USTR is set to hold hearings in connection with these investigations on April 28, 2026, with all interested parties having been invited to submit testimony by April 15. Figure 1 shows the full list of economies subject to the new Section 301 investigations.

Read more: The US tariff timeline of trade tensions and tariff changes

Automotive Logistics tracks the escalation month by month in this timeline overview, with the latest developments as the US prepares for tariff refunds after the Supreme Court ruled Trump's IEEPA global tariffs illegal.

The launch of these investigations follows the US Supreme Court's decision that US president Donald Trump was not authorised by the International Emergency Economic Powers Act (IEEPA) to impose global tariffs on the so-called 'Liberation Day' in April 2025. 

After the 'Liberation Day' tariffs were struck down, Trump imposed a new 10% "temporary import surcharge" under Section 122 of the Trade Act of 1974; however most finished vehicles and automotive parts were granted an exemption from this tariff.

"The policy hasn't changed," Greer told ABC News after the Supreme Court's decision was announced. "The legal tool to implement it – that might change, but the policy hasn't changed."

There are currently a number of Section 301 tariffs already in effect relating to vehicles and automotive components, although most are aimed at imports from China, as Figure 2 shows.