Trump Administration Faces Growing Trade Challenges Amid USMCA Review and Forced-Labor Tariff Proposals
The U.S. trade representative (USTR) has already issued a determination under Section 301 of the Trade Act of 1974 concerning forced‑labor practices in 60 economies. The USTR’s report, published in the Federal Register on June 5, found that each of the 60 countries failed to impose or enforce a prohibition on imports produced with forced labor in a manner that is unreasonable, discriminatory, or burdens U.S. commerce. The agency has proposed additional duties of 10 % for countries that commit to enforce such prohibitions and 12.5 % for all other countries. Hearings on the proposed duties are scheduled for July 7, 2026, with written comments due by July 6.
Congressional pressure has intensified. A bipartisan group of 48 Republican representatives has asked the USTR to launch a Section 301 investigation into foreign sugar trade practices and the rise in out‑of‑quota imports. Separately, a letter from Senators Elizabeth Warren (D‑MA) and Mark Kelly (D‑AZ) urged the administration to reimpose port fees on Chinese vessels that were lifted last year as part of a trade deal.
The Trump administration’s tariff agenda has expanded beyond the USMCA review. The USTR’s list of proposed duties includes a 25 % tariff on Brazil for a range of digital‑trade and intellectual‑property issues, a 10 % tariff on China for all products, and a 12.5 % tariff on imports from Nicaragua for the period 2026‑2028. Additional measures target critical minerals, semiconductors, and aluminum, with certain aerospace products from the United Kingdom exempt.
The administration has also announced variable‑rate duties on goods from countries that have sold oil to Cuba or imported Venezuelan oil, and a 25 % duty on imports from any country that imports Venezuelan oil. A 100 % tariff on movies produced outside the United States and a 200 % tariff on pharmaceuticals are also on the table.
The USTR’s forced‑labor investigation is part of a broader strategy to use Section 301 as a tool for trade enforcement. The agency’s determination was issued on June 2, and the proposed duties will apply to virtually all U.S. imports from the 60 countries. The USTR has indicated that companies can assess exposure by reviewing the tariff schedule and that the agency will provide guidance on compliance.
The USMCA review itself is a significant political event. Canada’s trade minister, Dominic LeBlanc, wrote to U.S. and Mexican counterparts on June 1, urging renewal of the agreement and noting its benefits. The U.S. has, however, expressed concerns about trade deficits and the need to protect domestic manufacturing.
The combination of a potential USMCA expiration, new forced‑labor tariffs, and congressional calls for further investigations creates a complex trade environment. The U.S. must navigate the legal framework of Section 301, the obligations under the USMCA review process, and the political expectations of both domestic industries and foreign partners.
As of now, the U.S. has not implemented the proposed forced‑labor duties; they remain in the proposal stage pending the July 7 hearings. The USMCA review will begin on July 1, and the outcome will be determined by the joint committee of the U.S., Mexico, and Canada. The administration’s next steps will involve negotiating the terms of any renewal, responding to congressional requests for investigations, and preparing for the USTR hearings.
The situation remains fluid. Key dates include the July 1 start of the USMCA review, the July 7 USTR hearings, and the July 6 deadline for written comments on the forced‑labor tariffs. The administration’s decisions in the coming weeks will shape U.S. trade policy for the next decade.