Administration Imposes Broad Forced-Labor Section 301 Tariffs as Section 122 Surcharge Expires - The National Law Review
The administration has imposed broad forced-labor Section 301 tariffs as the Section 122 surcharge expires, increasing costs and compliance burdens for importers of goods linked to forced labor, particularly from China.
Aforeworn detected this change in the Small Cross-Border Importers space on July 24, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. China-sourced sellers, apparel importers, electronics importers, dropship-to-DTC businesses should confirm how it applies to their specific situation before acting. There is a time constraint attached: Immediately; tariffs are effective upon publication.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Small Cross-Border Importers continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
Section 301 tariffs are now applied to goods suspected of forced labor, replacing the expired Section 122 surcharge, with broader scope and higher duties.
Who it affects
China-sourced sellers, apparel importers, electronics importers, dropship-to-DTC businesses
What you must do
Review supply chains for forced labor risks, update HS code classifications, and prepare for increased tariffs and potential CBP audits.
Deadline
Immediately; tariffs are effective upon publication.
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