CRITICAL: Türkiye Among 60 Economies Facing Section 301 Forced Labor Duties — 10–12.5% Additional Tariffs Proposed

The United States Trade Representative (USTR) has made a formal determination that 60 economies — including Türkiye, China, the United Kingdom, the United Arab Emirates, South Korea, Japan, India, Brazil, and others — failed to impose or effectively enforce prohibitions on the importation of goods made with forced labor. Based on this determination, USTR has proposed additional duties of 10% for certain economies and 12.5% for others under Section 301 of the Trade Act of 1974.

Written comments were due July 6, 2026, with public hearings scheduled for July 7, 2026. This is one of the most significant trade enforcement actions affecting Türkiye–U.S. trade in recent years.

Section 301 of the Trade Act of 1974 authorizes the USTR to investigate and respond to foreign government practices that are "unreasonable or discriminatory" and burden or restrict U.S. commerce. USTR's forced labor investigation focused on whether the 60 listed economies have:

• Enacted laws prohibiting the importation of goods made with forced labor
• Effectively enforced those prohibitions through customs enforcement, supply chain audits, and import restrictions
• Cooperated with U.S. enforcement efforts, including sharing information about forced labor in supply chains

USTR determined that all 60 economies fell short on one or more of these criteria, and that this failure constitutes an unreasonable practice that burdens U.S. commerce by allowing goods made with forced labor to compete unfairly with goods produced under lawful labor conditions.

USTR proposed two tiers of additional duties:

• 10% additional duty: For economies with partial enforcement failures or where cooperation with U.S. enforcement efforts has been limited
• 12.5% additional duty: For economies with more significant enforcement failures or where forced labor in supply chains is more pervasive

The proposed duties would apply to all goods from the listed economies — not just goods in specific sectors — unless an importer can demonstrate that the specific goods were not produced with forced labor.

Türkiye is a significant exporter to the United States across multiple sectors. The proposed additional duties, if imposed, would affect:

Turkey is one of the world's largest textile and apparel exporters. Turkish textile and apparel exports to the U.S. — including cotton fabrics, synthetic fibers, knitted garments, and finished apparel — would face additional duties on top of existing tariff rates. For many product categories, the combined tariff burden could make Turkish goods significantly less competitive against goods from countries not subject to the proposed duties.

Turkish manufacturers export a wide range of industrial goods to the U.S., including steel products, aluminum, chemicals, machinery components, and automotive parts. The proposed duties would apply across these categories.

Turkish consumer goods — including food products, ceramics, glass, furniture, and household items — would also be subject to the proposed duties.

Products assembled or processed in Türkiye using inputs from third countries present particular compliance challenges. Even if the Turkish manufacturing process itself does not involve forced labor, inputs sourced from other countries on the USTR list could create compliance exposure.

The USTR's Section 301 action is separate from, but related to, the Uyghur Forced Labor Prevention Act (UFLPA), which creates a rebuttable presumption that goods produced in the Xinjiang region of China involve forced labor. The Section 301 action is broader — it targets enforcement failures across 60 economies, not just China.

However, the UFLPA's framework for rebutting the forced labor presumption — through supply chain tracing, supplier audits, and documentation — provides a useful model for how importers can demonstrate that their goods were not produced with forced labor under the Section 301 framework.

USTR's determination focuses on whether economies "effectively enforce" forced labor prohibitions. This standard has implications for Turkish companies:

• Turkish law prohibits forced labor, and Turkey has ratified the relevant ILO conventions
• However, USTR's determination suggests that enforcement of these prohibitions in practice has been insufficient
• Turkish companies exporting to the U.S. should be prepared to demonstrate that their specific supply chains are free from forced labor — not just that Turkish law prohibits it

1. Map your supply chain: Identify all suppliers, sub-suppliers, and input sources for goods exported to the U.S. Document the country of origin for all inputs and the manufacturing processes at each stage

2. Conduct forced labor risk assessments: Evaluate each supplier and input source for forced labor risk, using recognized frameworks such as the ILO's indicators of forced labor, the OECD Due Diligence Guidance, and the U.S. Customs and Border Protection (CBP) Forced Labor Enforcement Guidance

3. Obtain supplier declarations: Require all suppliers to provide written declarations that their goods and inputs were not produced with forced labor, and that they will cooperate with audits and inspections

4. Review origin documentation: Ensure that certificates of origin, commercial invoices, and other customs documentation accurately reflect the country of origin and manufacturing process for all goods

5. Audit high-risk suppliers: For suppliers in high-risk sectors or regions, conduct or commission independent audits to verify the absence of forced labor

Turkish companies with U.S. export contracts should review and update their agreements to address forced labor compliance:

Supplier warranty clauses: Include representations and warranties from suppliers that goods were not produced with forced labor, with indemnification obligations for breach.

Audit rights: Include the right to audit suppliers' facilities and records for forced labor compliance.

Tariff change clauses: Include provisions allocating the risk of additional duties between buyer and seller, with price adjustment mechanisms if duties are imposed.

Indemnification provisions: Include indemnification obligations for losses arising from forced labor violations in the supply chain, including additional duties, import restrictions, and reputational harm.

Termination rights: Include the right to terminate supplier agreements if forced labor violations are discovered.

Importers seeking to rebut a forced labor presumption under the proposed Section 301 framework will need to maintain comprehensive documentation, including:

• Supply chain maps showing all suppliers and input sources
• Supplier declarations and audit reports
• Origin documentation for all inputs
• Evidence of due diligence procedures and their results
• Records of any remediation actions taken in response to identified risks

The textile and apparel sector faces the highest forced labor compliance risk due to complex, multi-tier supply chains involving cotton, yarn, fabric, and finished garments from multiple countries. Turkish textile exporters should:

• Trace cotton inputs to the farm level where possible
• Obtain certifications from cotton suppliers (e.g., Better Cotton Initiative, GOTS)
• Conduct factory audits at all manufacturing stages
• Maintain documentation of all supply chain participants

Turkish manufacturers should focus on:

• Identifying inputs sourced from high-risk countries (particularly China, where UFLPA creates additional compliance obligations)
• Documenting the manufacturing process and value-added in Türkiye
• Obtaining supplier declarations from all input suppliers

U.S. importers of Turkish goods should:

1. Notify Turkish suppliers of the proposed Section 301 action and request supply chain documentation
2. Review import contracts for tariff change clauses and forced labor compliance provisions
3. Assess the financial impact of 10–12.5% additional duties on product economics
4. Develop contingency plans for sourcing alternatives if duties are imposed
5. Engage customs counsel to assess classification and origin issues that could affect duty exposure

• July 6, 2026: Written comment deadline (passed)
• July 7, 2026: Public hearings
• Post-hearing: USTR will review comments and hearing testimony before issuing a final determination
• Final determination: Could be issued within weeks to months of the hearings; duties would take effect upon publication in the Federal Register

ULF New York advises Turkish companies, U.S. importers of Turkish goods, and multinational companies with Türkiye-linked supply chains on U.S. trade law, forced labor compliance, supply chain due diligence, and cross-border contract structuring. Contact us for an urgent consultation on Section 301 forced labor compliance.