Summary
The Office of the United States Trade Representative (USTR) has imposed new tariffs on imports from 60 trading partners. Most covered goods will now face a 10% or 12.5% tariff, depending on their country of origin, with some products exempt.
The tariffs took effect on July 24, 2026, as the temporary Section 122 surcharge expired. Importers should review product classifications, existing duties, exemptions and country-specific rates to understand the impact on landed costs.
What is it?
USTR has taken final action in 60 Section 301 investigations involving 59 countries and the European Union. The investigations examined these trading partners’ failure to impose and effectively enforce prohibitions on importing goods produced with forced labor.
These are new tariffs. There was no existing universal 12.5% forced-labor tariff.
The final tariff structure includes:
The tariffs generally apply to most imports from the covered markets. However, certain products are exempt, including goods already subject to Section 232 tariffs and other product-specific exclusions identified by USTR.
Existing duties may still apply alongside the new tariffs. For China, existing Section 301 tariffs are product-list-based rather than universal. Lists 1–3 generally carry a 25% tariff, while List 4A generally carries a 7.5% tariff.
For example, a Chinese product with a 10% MFN duty and an existing 7.5% List 4A tariff could face a total duty of 30% after adding the new 12.5% tariff. A product carrying an existing 25% List 1–3 tariff could face a total duty of 47.5%, before any other applicable duties or fees.
When
USTR launched the forced-labor investigations on March 12, 2026, and published its findings and proposed tariffs on June 2. Following a public comment period and hearings held July 7–9, USTR announced its final action on July 23.
The new tariffs took effect at 12:01 a.m. ET on July 24, 2026, as the temporary Section 122 surcharge expired.
A limited exception applied to goods already in transit before the effective time, provided they entered the United States before 12:01 a.m. ET on July 28, 2026.
Who it Affects
This action affects U.S. businesses importing covered goods from the 59 countries and the European Union included in the Section 301 action.
The impact depends on:
Importers sourcing from China and Brazil should pay particular attention. Chinese products may already be subject to list-based Section 301 tariffs of 7.5% or 25%, while certain Brazilian goods may face additional commodity-specific measures. These duties could apply alongside the new country-wide tariff and materially increase landed costs.
Why it matters
These tariffs introduce a significant new landed-cost consideration for businesses importing from the 59 covered countries and the European Union.
The impact will vary by product. There is no single 37.5% cumulative rate. Total duty exposure will depend on the product’s country of origin, HTSUS classification, normal MFN duty, applicable exemptions and any existing trade remedies.
Some duties may still stack. Although there was no existing universal 12.5% forced-labor tariff, the new 10% or 12.5% tariff may apply alongside existing product-specific duties. This is particularly important for Chinese goods already subject to list-based Section 301 tariffs.
The tariffs are already in effect. USTR announced its final action on July 23, and the new rates took effect on July 24 as the temporary Section 122 surcharge expired. Businesses now need to confirm that their duty and landed-cost calculations reflect the change.
Pricing and margins may be affected. Importers that cannot absorb the additional cost may need to adjust product pricing, sourcing strategies, supplier agreements or tariff-escalation provisions.
Product-level visibility is essential. Applying one blanket assumption across an entire market could produce inaccurate costs. Every affected product should be reviewed based on its origin, classification and complete tariff profile.
What Brands Should Do Now
Review affected products by country of origin, HTSUS classification, MFN duty, exemptions and existing trade remedies. Understanding the complete tariff profile will help brands update landed-cost calculations, adjust pricing and protect margins.
Current FlavorCloud customers are protected from unexpected costs, with these tariff changes incorporated into landed-cost calculations and pricing at checkout.
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