Trade Policy Update: Two New Section 301 Investigations Put Importers on Notice

USTR has opened two new Section 301 tracks targeting forced labor import prohibitions and structural excess capacity. Here’s where the exposure sits and what importers should do before the April 15 deadline.

Trade policy just got more complex again.

On March 11 and 12, the Office of the U.S. Trade Representative launched two new Section 301 investigation tracks that could lead to additional tariffs or other import restrictions affecting a wide range of countries, industries, and sourcing strategies. USTR announced one set of investigations tied to forced labor import prohibitions and another tied to structural excess capacity and production in manufacturing sectors.

These investigations are still in the record-building stage. That matters because this is the window when importers still have time to assess exposure, model cost impact, and decide whether they need their business realities reflected in the official record. USTR’s fact sheets make clear the scope is broad, and the agency has already published notice documents for comments and hearings.

What Is Under Review

The first track focuses on forced labor import prohibitions.

USTR is examining whether 60 economies that do not adequately prohibit imports made with forced labor are creating unfair conditions for U.S. commerce. According to USTR’s fact sheet on the forced labor investigations, the scope includes major trading partners such as China, the European Union, Canada, Mexico, India, Vietnam, South Korea, and Japan.

The second track focuses on structural excess capacity.

Here, USTR is examining whether 16 economies are creating artificial production capacity beyond global demand in ways that burden U.S. commerce. In USTR’s fact sheet on structural excess capacity, the sectors identified include steel, aluminum, autos and parts, batteries, solar, semiconductors, electronics, chemicals, robotics, and machinery.

That combination matters. It means the risk is not limited to one lane, one product category, or one supplier market.

Why Mallory Customers Should Care

This is the kind of development that can move from policy headline to landed-cost reality faster than many companies expect.

The forced labor investigation reaches across a huge share of U.S. import exposure. The structural excess capacity investigation reaches across sectors that sit deep inside industrial supply chains. Together, they create a real possibility of fresh tariffs, tighter import restrictions, or new cost and sourcing pressure. Companies that have been following Mallory’s recent compliance content, including Global Trade and Compliance: 5 Updates to Act On for 2026, Why Trade Compliance Matters Now More Than Ever, and our earlier Section 301 coverage like U.S. Introduces Maritime Fees to Counter China’s Shipbuilding Dominance, know how quickly trade actions can move from policy discussion to operational cost.

The practical risk for importers is delay in decision-making.

If companies wait until a final action is announced, they are already reacting late. By that point, procurement teams may be scrambling, landed-cost models may be outdated, customer pricing may be exposed, and supplier conversations may already be behind the curve.

Key Deadlines

Importers should treat the comment window as a live planning deadline, not a procedural footnote.

USTR’s notice materials say written comments and hearing requests are due by April 15, 2026. Public hearings begin April 28, 2026 for the forced labor track and May 5, 2026 for the structural excess capacity track. The relevant notice documents are the forced labor investigation notice and the structural excess capacity investigation notice.

What Importers Should Do Now

1. Review supply chains tied to the economies under review.
2. Identify which products and customers are most exposed.
3. Model tariff and landed-cost impact under multiple scenarios.
4. Decide whether your business should submit comments or request a hearing.
5. Prepare sourcing, pricing, and customer teams for potential policy movement.

The businesses that prepare now will be operating from analysis. The ones that wait will be operating from urgency.

Where Does Mallory Alexander Fit In?

This is exactly where Mallory Alexander can help customers translate policy into action.

For companies trying to connect customs, landed cost, sourcing risk, and execution planning, this update fits squarely inside the work we have been highlighting in Global Trade and Compliance: January Update for Shippers and Why Trade Compliance Matters Now More Than Ever. The right response to a new Section 301 investigation is not panic. It is structured preparation.

April 15 is closer than it looks. The right move now is to understand your exposure before the next round of action lands.