On a 11 May deadline, Vogue Business reports on the effect of tariffs on forced labor trends:
Tara Donaldson | May 11, 2026
As part of a new investigation designed to examine how well US trading partners are keeping forced labor out of their supply chains, the Office of the United States Trade Representative (USTR) is currently evaluating whether it can impose Section 301 tariffs on countries that aren’t doing such a great job. While President Trump had previously imposed Section 301 reciprocal tariffs under the out moded International Emergency Economic Powers Act (IEEPA), which the Supreme Court ruled in February he couldn’t invoke, forced labor is the new avenue he’s taking to reinstate the previous tariffs.
The stopgap Section 122 10% tariffs that were upheld by the Supreme Court are slated to expire on July 24, and a lull between that and the next batch is unlikely. “I anticipate by July 24, we’ll see these new tariffs announced, maybe even before,” says Julia K. Hughes, President of the United States Fashion Industry Association (USFIA).
There are 60 countries on Trump’s latest target list — which spans all of fashion’s key producers, including Bangladesh, China, and Vietnam, and accounts for more than 99% of US imports. It’s “the broadest tariff trigger ever used under Section 301”, Strickler says, and it could lead to across-the-board tariffs on imports from so-deemed non-compliant countries. Textiles and apparel are at the greatest risk.
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Tariffs are too indirect to be similarly effective, says Hughes. Forced labor risk is often embedded deep upstream, while tariffs hit the import transaction at the border. Imposing tariffs doesn’t necessarily create a clean break with tainted supply or require traceability either. And for the pressure of punitive duties to work, the economic pain has to exceed the cost of changing labor practices.
The tariff may be high enough to effect change, but whether it adequately addresses forced labor remains to be seen. Certainly, fashion will take a hit either way. The new tariffs are intended to replace the previous Section 301 reciprocal tariff and could similarly reach as high as 25%, depending on the country. Looking at Europe specifically, where forced labor standards are often tougher than in the US, a big question, Hughessaid, is whether the EU will be hit by this.
“It’s hard to read the tea leaves,” Hughes adds. “I would expect that there would be different tariffs for different countries since there’s a focus on some countries more than others.” Combined, these two investigations are intended to yield at least the same tariff rate asthe reciprocal 301 and “maybe higher”, says Hughes.
At the end of April, USTR also released its annual Special 301 Report, looking at the global state of intellectual property protection. In it, they named Vietnam as a target they could open a case against for IP violations. The US is “ratcheting up the pressure onVietnam”, says Hughes, adding that this could serve as yet another avenue for the administration to raise tariffs on the second largest supplier of clothing to the US.
“They’re looking for all mechanisms to be able to have the threat of tariffs,” says Hughes. “We don’t really have any indicators of where this might go.”