In the past few months, the U.S. Supreme Court invalidated the International Emergency Economic Powers Act (IEEPA) tariffs, while the U.S. Court of International Trade (CIT) ruled against the Trump administration’s subsequent Section 122 10% global tariff rate. As companies scramble to obtain tariff refunds, many are questioning the longevity of those remaining tariffs. Specifically, the Office of the U.S. Trade Representative has initiated a review of Section 301 tariffs on imports from China. Section 301 is part of the 1974 Trade Act, which targets, “unjustifiable, unreasonable, or discriminatory foreign government practices that burden or restrict U.S. commerce,” including forced labor.
Introduced in 2018 in the first Trump administration, these specific tariffs levy 7.5% to 25% tariffs on a range of Chinese products, from medical equipment to tungsten products. Even if the review of Section 301 shifts in approach, broader U.S. and E.U. policies address the removal of forced labor from supply chains through trade restrictions and export controls. While that may not stabilize the tariff fluctuations, there are expanding regulatory frameworks that continue to mandate the monitoring of and visibility into forced labor in corporate supply chains.
The Regulatory Landscape
The U.S. Department of Labor’s 2024 List of Goods Produced by Child Labor or Forced Labor (TVPRA list) identifies 204 products produced using forced labor in 82 countries. In March 2026, the U.S. Trade Representative initiated investigations across 60 countries to assess compliance of enforcement and prohibition of goods produced with forced labor. In addition, the Uyghur Forced Labor Prevention Act (UFLPA) specifically targets the Xinjiang Autonomous Region in China, restricting any goods made from that region under the presumption that they are made with forced labor. Between FY 2022 and FY 2026, almost 42,000 shipments valued at $3.9B have been impacted by UFLPA enforcement actions.
The EU Forced Labor Regulation (FLR) will prohibit the sale of products into the EU market that are linked to forced labor beginning in December 2027. A former member of the EU Parliament noted, “Ultimately, it is a significant step toward meaningful supply chain reform and can ensure that products entering the EU are free from forced labor.” This is similar to the EU Deforestation Regulation in that it is product-focused, as opposed to targeting a region like the UFLPA. To prepare for the regulation, due diligence into the lifecycle of goods and the presence of forced labor at any stage of the lifecycle.
Supply Chains at Risk
According to the International Labor Organization, 27.6M people are subjugated to forced labor, 63% of which occurs in the private sector. Given the human and regulatory impact, continuous monitoring and proactively identifying suppliers at risk of unethical labor should be integrated into any supply chain risk management framework.
Over the last year alone, interos.ai has identified almost 600 unethical labor events based on public reporting. At the same time, based on geographic location, product-risk, and human-rights related trade restrictions, interos.ai identifies over 1.3M companies at high risk for unethical labor. Almost 80% of these companies are in China and India and almost half of which directly supply companies in the U.S. These companies, in turn, introduce risk across any supply chain in which they are a supplier. Across tiers 1 through 3, over 10.7 companies may be exposed to unethical labor due to the presence of these companies in their supply chains. The most prominent industries among the exposed companies are: Consumer Goods, Apparel Manufacturing, Apparel Retailers, Computers and Computer Peripheral Manufacturing and Sales, and Prepared Food Manufacturing.
The China Question
With President Trump’s visit to China this week, Iran, AI, and global trade and US-China trade relations will be dominant topics. Given recent U.S. Supreme and Federal court rulings, Section 301 and Section 232 tariffs are among the last tariffs standing. Each of these target China, albeit under the broader auspices of forced labor and raw and critical minerals.
This week may prove consequential for Section 301 tariffs as China is likely to push for friendly policies. Regardless of actions taken on those tariffs, forced labor remains under a growing regulatory landscape within the U.S. and E.U. through a range of export controls and sanctions. At the same time, this week’s meetings between leaders of the world’s largest economies likely will have some impact on global supply chains. Supply chain weaponization remains a key tool of statecraft, one that not only impacts forced labor globally, but extends far into global conflicts and the AI race.