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New U.S. trade actions: Section 232 tariff adjustments, importer of record reform, and proposed Section 301 forced labor tariffs

Date of publication: June 25, 2026.
The U.S. trade compliance landscape continues to shift quickly. In early June 2026, the Administration issued three significant actions affecting tariffs, importer accountability, customs enforcement, and forced labor compliance.
These actions are especially relevant for importers, customs brokers, manufacturers, retailers, e-commerce sellers, foreign Importers of Record, and companies with global supply chains.

Quick summary

  • Section 232 tariff adjustments:
     A Presidential Proclamation signed June 1, 2026, adjusts certain Section 232 tariffs on steel, aluminum, and copper products. The changes take on
    June 8, 2026
    . Some affected agricultural equipment, residential HVAC systems, and mobile industrial equipment may qualify for reduced temporary rates through
    December 31, 2027
    .
  • Importer of Record and customs enforcement reform:
     An Executive Order signed June 3, 2026, directs DHS and CBP to strengthen customs enforcement, including more rigorous Importer of Record requirements, higher bond expectations, new “good standing” requirements, supply chain disclosures, and increased penalties.
  • Proposed Section 301 forced labor tariffs:
    A USTR June 2, 2026 Report has concluded that 60 economies have failed to impose and effectively enforce forced labor import prohibitions. USTR has proposed additional duties of 10% for certain economies with some forced labor import controls and 12.5% for others. These tariffs are proposed only and are not yet in effect. Written comments are due
    July 6, 2026
    , and hearings are scheduled for
    July 7, 2026
    .

1. Section 232: targeted tariff adjustments for steel, aluminum, and copper

The June 1 Proclamation adjusts — but does not eliminate — existing Section 232 tariffs on steel, aluminum, copper, and certain derivative products. Section 232 tariffs are national-security-based tariffs that have applied to steel and aluminum since 2018, with copper added in 2025.
What changed?
The June 2026 action provides targeted, temporary tariff adjustments for certain product categories, including:
  • Agricultural equipment
    , including certain combines and harvesters.
  • Residential HVAC systems
    .
  • Mobile industrial equipment
    , such as certain bulldozers and forklifts, from specified trade-deal countries.
  • Certain goods using
    85% or more U.S.-origin steel or aluminum content
    , which may qualify for a lower
    10%
     duty rate if documentation requirements are met.
  • Newly covered product categories, including
    aluminum lithographic plates
     and
    steel racks
    .
The White House has stated that these tariff changes are temporary and last until
December 31, 2027
.
Why it matters
Importers that previously modeled tariff exposure based on higher April 2026 rates should reassess whether their products now qualify for a reduced temporary rate. This may be especially important for companies importing agricultural equipment, HVAC products, industrial machinery, or products with substantial U.S.-origin metal content.
However, eligibility will depend on product classification, country of origin, the applicable HTS provisions, and the ability to support any U.S.-content claim with documentation. Importers should confirm with their trade counsel.

2. Importer of record reform: more documentation, more scrutiny, higher penalties

The June 3 Executive Order directs DHS and CBP to strengthen customs enforcement and modernize Importer of Record requirements. The Administration has described the action as targeting duty evasion, undervaluation, shell-company import structures, and misuse of entry processes.
Key areas to watch
The EO points to several changes that may affect importers and brokers, including:
  • Higher or more stringent bond requirements.
  • A new Importer of Record "good standing" requirement.
  • Additional IOR vetting and disclosure obligations.
  • More supply chain information and product-level detail.
  • Forced labor compliance certifications or disclosures.
  • Greater oversight of customs brokers.
  • Increased penalties, including a
    50% minimum penalty floor
     limiting CBP's discretion to reduce assessed penalties for customs law violations.
Foreign IORs may see the greatest impact
Companies that import into the United States through foreign IORs, offshore procurement entities, sourcing subsidiaries, or other nonresident structures should pay close attention. The internal brief highlights that foreign IORs may face:
  • Limits on informal entries.
  • Stricter bond requirements.
  • Potential restrictions on use of continuous bonds.
  • CTPAT validation requirements or a requirement to use a CTPAT-validated broker for formal entries.
  • Increased scrutiny of entities without a genuine U.S. presence.
Why it matters
This action does not shift responsibility away from the Importer of Record. The IOR remains legally responsible for customs entry accuracy, duty payment, and compliance with U.S. trade laws. But brokers may also face increased accountability, which means importers should expect more questions, more documentation requests, and possibly tighter broker onboarding or transaction review procedures.
Most requirements are expected to roll out over
90- to 180-day implementation windows
, so customers should begin planning now rather than waiting for final operational changes.

3. USTR Section 301 forced labor report: proposed tariffs on 60 economies

On June 2, 2026, USTR issued findings in 60 Section 301 investigations involving foreign economies’ alleged failure to impose and effectively enforce prohibitions on imports of goods made with forced labor. USTR determined that these acts, policies, and practices are unreasonable or discriminatory and burden or restrict U.S. commerce.
What USTR has proposed
USTR has proposed:
  • A
    10% additional duty
     for certain economies that have some forced labor import measures, have committed to adopt and enforce such measures, or have partial regimes.
  • A
    12.5% additional duty
     for other investigated economies.
  • A separate textile mechanism that may allow reduced rates for certain apparel and textile volumes.
  • A public comment process, with written comments due
    July 6, 2026
    .
  • Public hearings scheduled for
    July 7, 2026
    .)
Not yet in effect
These proposed Section 301 tariffs are
not currently in effect
. Final action would follow after the comment and hearing process.
Why it matters
If finalized, these tariffs would likely stack on top of existing duties, including ordinary customs duties, Section 232 duties, antidumping or countervailing duties where applicable, and existing Section 301 duties.
The scale is significant. This is not limited to China. USTR’s action covers 60 economies, including many major U.S. trading partners and common sourcing locations. Companies that diversified sourcing away from China may still find alternative sourcing countries within scope of the proposed action.
This also signals that forced labor compliance is becoming not only a reputational and admissibility issue, but also a tariff and landed-cost issue.

Customer considerations

Trade professionals should consider the following steps now in conjunction with your trade compliance teams, customs brokers, or trade counsel:
  1. Review affected HTS classifications.
    Confirm whether imported goods fall within the updated Section 232 annexes or could be affected by proposed Section 301 forced labor duties.
  2. Revisit landed-cost models.
    Companies importing agricultural equipment, HVAC systems, mobile industrial equipment, steel or aluminum derivatives, or goods from countries covered by the USTR forced labor action should update duty exposure scenarios.
  3. Validate origin and content claims.
    For Section 232 purposes, review country of origin, steel or aluminum content, U.S.-origin metal content, and supporting supplier documentation.
  4. Assess Importer of Record structures.
    Companies using foreign IORs, offshore procurement entities, sourcing subsidiaries, marketplace sellers, or third-party import models should review whether those structures may be affected by new IOR requirements.
  5. Talk to brokers and compliance partners.
    Ask customs brokers how they are preparing for increased IOR vetting, documentation requirements, bond changes, and broker accountability expectations.
  6. Strengthen forced labor due diligence.
    Review supply chain visibility beyond Tier 1 suppliers. Maintain documentation on supplier sourcing, production locations, labor-risk indicators, and forced labor compliance controls.
  7. Centralize import data and audit trails.
    These actions point toward more scrutiny of classification, valuation, origin, admissibility, IOR eligibility, and forced labor compliance. Centralized records and clear audit trails will help companies respond more effectively.
  8. Monitor key dates.
    • June 8, 2026:
       Section 232 rate adjustments take effect.
    • June 22, 2026:
       Deadline to request to appear at USTR forced labor hearings.
    • July 6, 2026:
       USTR written comment deadline for forced labor/ 301 duties proposal.
    • July 7, 2026:
       USTR public hearings on forced labor/ 301 duties proposal.
    • Approx. September 2026:
       90-day actions under customs enforcement EO expected.
    • Approx. December 2026:
       180-day actions under customs enforcement EO expected.
    • December 31, 2027:
       Temporary Section 232 reduced rates expire.
  9. Consult trade counsel for legal or strategic decisions.
    Companies considering IOR restructuring, sourcing changes, comment submissions, or product-specific tariff positions should consult qualified trade counsel.

Bottom line

These three actions reflect a broader shift toward higher trade enforcement expectations, more importer accountability, and expanded use of tariffs to address supply chain and forced labor concerns.
For customers, the immediate priorities are to confirm whether products are affected, update landed-cost assumptions, review IOR structures, strengthen supplier documentation, and prepare for increased CBP scrutiny. Companies with centralized trade data, current classifications, and strong audit trails will be better positioned to respond as these requirements develop.