Key Points

• USTR held public hearings in July on a proposal to impose tariffs of 10-25% on nearly all imports from 60 economies that are being investigated for failing to effectively ban the importation of goods made with forced labor.
• Many witnesses urged a more targeted approach, including exemptions for specific products and nations.
• There is still time — one day — to respond to the testimony. Written comments are due Thursday, July 16, 2026.

The Office of the United States Trade Representative (USTR) conducted public hearings this month on its proposed Section 301 tariffs of 10–12.5% on nearly all imports from all 60 economies under investigation for forced labor import ban failures. Testimony was provided by a broad group of stakeholders, including foreign governments, industry groups, human rights advocates and domestic producers. As we previously reported, the proposed tariffs would apply across virtually all product categories, with limited exemptions. Here are some high-level takeaways from the hearings:

Cross-cutting pressure toward a targeted, phased approach. A recurring theme across retail, agriculture and consumer-brand witnesses — and notably even some human rights advocates — was significant opposition to a blanket, uniform tariff in favor of a more targeted and phased implementation. For example, witnesses called for product-specific exemptions and additional comment periods in the future to assess tariff levels and country classifications.

Government exemption requests. Several foreign governments highlighted existing or near-final bans on the importation of forced labor and requested consideration of tariff exemptions.

Immediate action item: rebuttal comments are due Thursday, July 16, 2026. This is the next — and potentially final — opportunity for interested parties to respond to the hearing record and other parties’ written comments before USTR moves toward a final tariff determination. Companies and other organizations with exposure to the proposed tariffs or other views should treat this deadline as a unique opportunity to rebut adverse positions in the record.

For more information, or assistance in submitting written comments in any USTR proceeding, please contact Mark Eskenazi at meskenazi@foxrothschild.com. Listen to Mark's podcast, "Labor Law Lineup," on Apple, Spotify, or wherever you get your podcasts.

This information is intended to inform firm clients and friends about legal developments, including the decisions of courts and administrative bodies. Nothing in this alert should be construed as legal advice or a legal opinion. Readers should not act upon the information contained in this alert without seeking the advice of legal counsel. Views expressed are those of the author and not necessarily this law firm or its clients.