The Office of the United States Trade Representative (USTR) released the results of its investigation under Section 301 of the Trade Act of 1974, determining that the practices, policies, and regulatory frameworks of 60 countries related to preventing imports produced with forced labor constitute an unreasonable practice that restricts and harms U.S. trade. As a result, the administration concluded that the practices of the 60 investigated economies are “unreasonable” and burden or restrict U.S. trade, and proposed additional tariffs ranging from 10% and 12,5%.
The decision represents one of the most significant developments in US trade policy in 2026 and constitutes the first concrete outcome of the investigations initiated by the Trump administration following the US Supreme Court's decision that struck down the so-called "reciprocal tariffs." In practice, these new investigations under Section 301 have become the administration's primary mechanism for rebuilding some of the tariff protection previously eliminated through the courts.
According to the report published by the USTR, the investigations assessed whether the United States' main trading partners have effective prohibitions to prevent the importation of goods produced wholly or partially through forced labor. The U.S. authority concluded that none of the 60 countries analyzed fully meet this objective.
The USTR distinguishes two elements: (i) imposing a prohibition on the importation of goods made with forced labor (understood as a legal and unequivocal prohibition that goes beyond requirements of transparency, due diligence, or disclosure) and (ii) effectively enforcing it. Based on this, it classifies the 60 economies into two groups:
Group and discovery | Economies |
6 economies They imposed a ban, but they don't enforce it effectively. | Canada, Ecuador, European Union, Indonesia, Mexico and Pakistan. |
54 economies They did not impose or enforce a ban. | Includes Colombia, in addition to China, India, Japan, South Korea, Brazil, the United Kingdom, Switzerland, Australia, Vietnam, Thailand and most other partners. |
Regarding the six jurisdictions with specific regulations prohibiting the import of goods produced with forced labor—Canada, Ecuador, the European Union, Indonesia, Mexico, and Pakistan—the report notes that these economies have not demonstrated effective enforcement and monitoring mechanisms to ensure actual compliance with these prohibitions. With respect to the European Union, it points out that the adopted regulations will not enter into force until 2027, so their implementation cannot yet be assessed.
Colombia, for its part, was included among the group of 54 economies that, according to the USTR, do not have a comprehensive ban on imports linked to forced labor and, therefore, do not meet the enforcement standard required by the United States. Along with Colombia, other countries on the list include Brazil, Argentina, Chile, Peru, the United Kingdom, Japan, South Korea, Australia, India, China, Vietnam, and Switzerland, among others.
For economies that impose an import ban on products made with forced labor, that have committed to imposing and enforcing such a ban through a Reciprocal Trade Agreement, or that have imposed a partial regime preventing the importation of certain products made with forced labor, the U.S. Trade Representative proposes an additional tariff of 10%. For the remaining economies, including Colombia, the proposal includes an additional tariff of 12,5% on imports to the United States.
The notice includes broad exclusions, listed in Annex A. The main categories are:
- All articles and parts already subject to national security tariffs under Section 232 of the Trade Expansion Act of 1962.
- Raw materials that, if taxed, could lead to the unavailability of domestic supply in the U.S.
- Products that could cause disruptions across the entire US economy if they were taxed.
- Certain products that cannot be grown or produced in sufficient quantities in the U.S. or obtained from other sources.
Additionally, the USTR proposes a textile mechanism that would allow a certain volume of apparel and textiles to enter the U.S. at a reduced rate under Section 301. A partner's reduced-tariff volume is linked to U.S. textile exports to that partner (e.g., U.S.-produced synthetic and cotton fiber inputs) and to the volume of U.S. cotton and cotton products that partner imports from the U.S. in a given period.
This would mean that Colombia, not having a ban on imports involving forced labor or a current Reciprocal Trade Agreement, would be subject to a 12,5% tariff, except for products excluded within Annex A and the textile mechanism.
It is important to note that this measure is a proposed action and is therefore not yet in effect, subject to the public consultation process prior to the USTR's final determination. Key dates to keep in mind are:
- June 22, 2026: Deadline to request to participate in the hearing and submit a summary of testimony.
- 6 July of 2026: Deadline for submitting written comments on the public record (docket USTR-2026-0133).
- 7 July of 2026: Public hearing of the Section 301 Committee on the proposed actions.
- Final determination by the USTR (final rates, Schedule A exclusions and effective date).
During the comment period, various countries and trade associations will be able to challenge the findings, request the exclusion of specific tariff lines, or propose technical cooperation. The USTR itself indicated that it will follow up with partners interested in cooperating to implement and enforce their own prohibitions.
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