Press Release: ICAR calls on the US government to implement a whole of government forced labor prohibition strategy along with Section 301 tariffs to drive forward enforcement globally

(June 8, 2026 | Washington, DC) On March 12th of this year, the United States Trade Representative (USTR) initiated investigations against the 60 economies that supply 99 percent of U.S. imports. The stated purpose of these investigations was to determine whether the practices of each economy as it pertains to forced labor were actionable under Section 301 of the Trade Act of 1974. On June 2nd, the U.S. government announced the completion of the Section 301 investigation, imposing a 10% tariff on economies that have imposed full or partial forced labor import bans or have committed to doing so, and a 12.5% tariff on all others. The United States bans the importation of goods produced with forced labor, notably under Section 307 of the Tariff Act of 1930 and, more recently, under the Uyghur Forced Labor Prevention Act of 2021 (UFLPA).

Despite various prohibition and enforcement mechanisms, forced labor goods continue to flow through U.S. supply chains, distorting markets and allowing bad actors to generate $236 billion in illegal annual profits. As of 2021,27.6 million people globally are subject to forced labor, over 3.3 million of whom are children. Though the U.S. accounts for thirteen percent of total global imports, it disproportionately imports over one fifth of all goods at risk of forced labor inputs.

Although ICAR welcomes the U.S. government leveraging its trade authority to pressure states into taking more concrete action to combat forced labor, a blanket tariff applied across all investigated economies is not the correct approach.

A strong and effective U.S. government strategy to combat forced labor in global supply chains should include:

• Thorough and consistent enforcement of Section 307 of the Tariff Act and other forced labor import bans, including the Uyghur Forced Labor Prevention Act (UFLPA).

• Transparent decision-making regarding withhold release order (WRO) removal based on the rule of law, rather than corruption. 

• The enactment of Human Rights Due Diligence requirements, including requirements for supply chain tracing and disclosure, and strengthening and enforcing U.S.-government procurement tools. 

• Diplomatic, foreign assistance, and technical assistance efforts to support enactment and effective implementation of forced labor import prohibitions and other actions to address the underlying causes of labor exploitation. 

• Intentional and evidence-based use of trade mechanisms based on an assessment of how and whether tariffs can be used to push countries to make improvements on their legislative or policy frameworks to complement U.S. enforcement against forced labor. 

• Strengthened efforts to address forced labor taking place within the U.S. 

We are not naive that this administration’s primary goal in imposing these tariffs does not appear to be enforcement against forced labor, but the imposition of tariffs through whatever tools are available. The U.S’s own forced labor import bans have been weakly enforced by this administration, resulting in a nearly 90% drop in value of shipments detained under the UFLPA between 2024 and 2025. The blanket application of tariffs does not address global discrepancies in the application of existing prohibitions, nor does it address the underlying market distortions that forced labor spurs. 

Despite this, we are hopeful that the Section 301 tariffs can be an effective advocacy tool for civil society in some states to advocate for the importance of adopting and enforcing forced labor import prohibitions. Moreover, ICAR will continue to engage with USTR to ensure that tariffs are used in a way to incentivize the development and strong enforcement of forced labor import bans in jurisdictions around the world. We will also continue to engage with Customs authorities to ensure full enforcement of the U.S. forced labor import bans. 

If the U.S. government truly seeks to combat forced labor in global supply chains, this administration should ensure that the Section 301 tariffs are part of a broader governmental effort that centers and prioritizes individuals facing or vulnerable to forced labor conditions globally, including through effective and thorough enforcement of existing forced labor import bans. We were pleased to see additional steps taken toward this through the “Strengthening Customs Enforcement” Executive Order, issued on June 3rd, which calls on Customs and Border Protection to increase transparency, including by requiring importers of record to provide additional data such as beneficial ownership and business affiliation disclosures. 

ICAR remains committed to combatting corporate human abuses throughout U.S. supply chains and ensuring that efforts to do so center workers and individuals impacted by global supply chains.