U.S. tariffs tied to forced labor allegations took effect on July 24, 2026, applying to imports from 86 countries at rates of 10% or 12.5%, according to a tracker maintained by Trade Compliance Resource Hub. The measure was published in the Federal Register on July 28, 2026, at 91 Fed. Reg. 47318. Trade partners have criticized the rationale behind the global duties, and the program is unfolding alongside separate litigation over other tariff authorities.
The tracker, compiled by Reed Smith's International Trade and National Security team, follows threatened and imposed U.S. tariffs as well as retaliatory measures from other governments. It sits within the administration's broader America First Trade Policy memorandum, which directs a review of tariff and tariff-adjacent tools available to advance the new trade agenda. President Trump has long described tariffs as central to his foreign policy approach.
Why it matters
The forced labor duties reach a large share of U.S. trading partners at once, including close allies and major manufacturing economies. That breadth makes the measure a significant shift in how Washington links labor concerns to import pricing, and it has already drawn objections abroad. For importers, the practical questions are which rate applies to their goods, which products are carved out, and how the new duties interact with other tariffs already in force.
How the rates break down
The 10% tier covers Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, the Philippines, Sri Lanka, Trinidad and Tobago, the United Kingdom and Vietnam.
The 12.5% tier applies to Algeria, Angola, Australia, The Bahamas, Bahrain, Brazil, Chile, China, Colombia, Costa Rica, the Dominican Republic, Egypt, Guyana, Hong Kong, Iraq, Israel, Kazakhstan, Kuwait, Libya, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, Qatar, Russia, Saudi Arabia, Singapore, South Africa, Thailand, Turkey, the United Arab Emirates, Uruguay and Venezuela.
Certain foreign-origin items are exempt from the forced labor tariffs. The exemption list names Bangladesh, Cambodia, China, the European Union, India, Indonesia, Japan, Malaysia, Mexico, Norway, Singapore, South Korea, Switzerland, Taiwan, Thailand and Vietnam. Several of those countries also appear on the duty lists, so importers will need to check whether specific goods fall under an exemption rather than assume a country-level rate applies across the board.
Court ruling adds uncertainty to separate duties
The forced labor action is not the only tariff front under legal challenge. On May 7, 2026, the Court of International Trade held that Proclamation 11012, which imposed Section 122 tariffs, was invalid as contrary to law, according to the tracker's litigation update dated May 8. The court stopped short of issuing a universal injunction that would bar U.S. Customs and Border Protection from collecting the duties or require refunds for all importers. The government has appealed.
That leaves importers facing a split picture: a judicial finding against the proclamation, continued collection at the border, and no blanket refund order while the appeal proceeds.
Stacking rules and the refund pipeline
The tracker notes that some duties always stack on top of any other applicable tariffs, and that product-specific Section 232 tariffs carry their own stacking rules. For companies paying multiple layers of duties, the order of calculation matters as much as the headline rate.
On the refund side, CBP launched Consolidated Administration and Processing of Entries, or CAPE, inside its Automated Commercial Environment on April 20, 2026. The system is meant to make it easier to submit and process valid IEEPA tariff refund requests. Only importers of record and customs brokers who filed the original entries can submit CAPE Declarations.
CAPE currently accepts declarations for unliquidated entries and for entries that liquidated within 80 days of a declaration being accepted, including entries flagged for reconciliation. Some entry categories are not yet accepted.
The government is appealing the part of the CIT order that would require CBP to process refunds on finally liquidated entries. Its current position, per the tracker, is that during CAPE Phase 3 only importers with pending refund cases before the court will be eligible for refunds on those entries. CBP expects electronic refunds to generally go out within 60 to 90 days of a declaration being accepted, though a compliance concern found during review can push that timeline back.
What to watch
Watch the government's appeal of the Section 122 ruling and the scope of CAPE refund eligibility as Phase 3 develops, since both determine whether importers recover duties already paid.
