76 New Section 301 Investigations: Comment Deadline Tracker (April 2026)
USTR opened 76 Section 301 investigations — 16 countries for manufacturing overcapacity and 60 for forced-labor enforcement. Written comments are due April 15, 2026, with hearings April 28–May 8.
The U.S. Trade Representative opened 76 Section 301 investigations in March 2026 — the largest single-month expansion of Section 301 activity since the tool was created in the 1974 Trade Act. If you import into the United States from more or less anywhere, you are probably named, directly or indirectly.
The two tracks split cleanly:
- 16 economies investigated for structural manufacturing overcapacity
- 60 economies investigated for failure to prohibit and enforce against goods made with forced labor
Written comments from U.S. importers, industry associations, and foreign governments are due April 15, 2026. Public hearings start April 28, 2026. This post is the fast tracker: who is covered, what the filing windows are, what USTR is actually asking, and what importers should do now.
⏰ Today's deadline: If you are reading this on or before April 15, 2026, written comments can still be submitted through the USTR portal. This is the primary chance for U.S. importers to get product-level and price-impact evidence on the record before hearings begin.
What actually happened
On March 12, 2026, USTR formally initiated two Section 301 investigations:
- Industrial / Structural Excess Capacity — targeting 16 trading partners whose production capacity, subsidies, and export patterns USTR argues are distorting U.S. and global industrial markets.
- Forced Labor Enforcement Failures — targeting 60 trading partners whose import controls, border enforcement, or supply-chain policies USTR argues fail to block goods produced with forced labor from entering commerce.
Each investigation is governed by Section 301(b) of the Trade Act of 1974, which allows USTR to recommend tariffs, import restrictions, or other remedies if foreign acts or policies are found "unreasonable or discriminatory" and burden U.S. commerce.
Translation for importers: if USTR finds against a country on either track, the most common remedy has historically been additional ad valorem duties, layered on top of existing MFN rates and any Section 232, IEEPA, or Section 122 tariffs already in place.
The 16 economies — overcapacity investigation
These are the economies named in the structural excess capacity investigation. The industries of greatest concern are metals, chemicals, shipbuilding, semiconductors, EVs and batteries, solar, and certain heavy machinery.
| Economy |
|---|
| Bangladesh |
| Cambodia |
| China |
| European Union |
| India |
| Indonesia |
| Japan |
| Korea (Republic of) |
| Malaysia |
| Mexico |
| Norway |
| Singapore |
| Switzerland |
| Taiwan |
| Thailand |
| Vietnam |
A few of these — China, Vietnam, Mexico, Korea, Taiwan — are completely unsurprising. Others, like Norway, Switzerland, Singapore, and the EU as a whole, are the reason this investigation has rattled compliance teams. The list moves beyond the "China-first" framing of earlier Section 301 actions.
The 60 economies — forced labor investigation
The forced labor track is a much wider net, aimed at whether each named economy effectively enforces its own bans on forced-labor goods and prevents those goods from transiting into U.S. commerce.
Named economies include:
Algeria · Angola · Argentina · Australia · The Bahamas · Bahrain · Bangladesh · Brazil · Cambodia · Canada · Chile · China · Colombia · Costa Rica · Dominican Republic · Ecuador · Egypt · El Salvador · European Union · Guatemala · Guyana · Honduras · Hong Kong (China) · India · Indonesia · Iraq · Israel · Japan · Jordan · Kazakhstan · Kuwait · Libya · Malaysia · Mexico · Morocco · New Zealand · Nicaragua · Nigeria · Norway · Oman · Pakistan · Peru · Philippines · Qatar · Russia · Saudi Arabia · Singapore · South Africa · South Korea · Sri Lanka · Switzerland · Taiwan · Thailand · Trinidad and Tobago · Türkiye · United Arab Emirates · United Kingdom · Uruguay · Venezuela
Allies sit next to adversaries in this list. Canada, the UK, Australia, New Zealand, and Israel are all named — not because USTR accuses them of tolerating forced labor, but because the investigation asks whether their enforcement mechanisms for banned goods meet USTR's standard. That framing matters for any company whose supply chain touches a U.S. ally as a transit or assembly point.
Comment deadline calendar
These are the key dates every importer, trade association, and foreign government is tracking right now. All times are U.S. Eastern.
| Date | Event | Who it affects |
|---|---|---|
| March 12, 2026 | Investigations initiated, Federal Register notices issued | Baseline — scope and questions on the record |
| April 15, 2026 | Written comments due (both tracks) | Importers, industry associations, foreign governments, NGOs |
| April 22, 2026 | Deadline to request to appear at forced-labor hearing (typical USTR window) | Parties seeking to testify April 28–May 1 |
| April 28 – May 1, 2026 | Public hearing — forced labor investigation | 60 named economies + interested U.S. parties |
| May 5 – May 8, 2026 | Public hearing — excess capacity investigation | 16 named economies + interested U.S. parties |
| ~7 days after each hearing | Post-hearing rebuttal comments due | Parties responding to testimony |
The exact windows for rebuttal filings depend on how each hearing concludes, but USTR's published procedure is seven calendar days from the end of the hearing. File early if possible — the portal slows down in the final hours.
What USTR is actually asking
This is the part many importers misread. USTR is not asking industry to justify tariffs. USTR is asking for factual evidence on specific questions, including:
Overcapacity track:
- Which foreign subsidies, industrial policies, or non-market practices drive the alleged overcapacity?
- Which sectors and HTS chapters are most affected?
- What is the magnitude of harm to U.S. producers, workers, and downstream buyers?
- What remedies would be effective, and what remedies would backfire on U.S. firms?
Forced-labor track:
- Does the country prohibit the importation of forced-labor goods by law?
- How effective is enforcement? Customs data, seizures, public reporting.
- Are there specific supply chains — cotton, polysilicon, seafood, palm oil, critical minerals — where enforcement is insufficient?
- What practical remedies are appropriate?
Comments that stay factual, data-rich, and specific tend to be cited in the final USTR report. Comments that read as political commentary tend not to move the record.
What importers should do now
The most productive 48 hours for a U.S. importer right now look like this:
1. Map your exposure to the 16 + 60 list
Start with country of origin on your last 12 months of entries. Any entry originating in one of the 16 overcapacity economies is higher-priority because the remedy is more likely to be sector-specific tariffs on HTS codes you already use.
2. Model a "Section 301 stack" scenario
Use the Duty Calculator to model your most exposed HTS codes with an additional 10% – 25% Section 301 layer on top of your current stack (MFN + any Section 232, IEEPA, or Section 122 duties already applied). This gives finance and procurement a real forecast range, not a vibe.
3. File a written comment if you have product-level data
If you have entry data, landed cost data, price elasticity data, or supplier concentration data — any of which USTR rarely gets from government sources — your comment has real marginal value. The comment portal is on regulations.gov under the relevant docket numbers referenced in the Federal Register notices.
You do not need an outside law firm to file. You do need to cite real numbers and avoid generalizations.
4. Flag upstream suppliers in the 60 economies for a UFLPA review
Even if the forced-labor investigation does not result in new tariffs, the evidence USTR collects feeds directly into UFLPA enforcement by CBP. If your supply chain touches cotton, polysilicon, seafood, palm oil, tomatoes, or critical minerals through any of the 60 named economies, assume tighter entry review within 90 days regardless of how the investigation concludes.
5. Diversify before the remedy phase, not after
The remedy phase comes after hearings. If you wait for the USTR report, you are competing for alternate suppliers with every other U.S. importer in your sector. The Sourcing Comparison tool can frame a first-pass country-by-country comparison before you commit to supplier audits.
How this relates to earlier Section 301 actions
Section 301 is most familiar to U.S. importers as the China tariff framework built up from 2018 onward. The 2026 investigations extend the tool in three important ways:
- Scope — 76 countries is not a typo. It is a deliberate expansion beyond China.
- Grounds — the "structural overcapacity" and "forced-labor enforcement failures" grounds are broader than earlier "unreasonable practices" framings. They implicate industrial policy and border enforcement, not just IP theft or market access.
- Timing — the 150-day review clock runs fast. Importers who treat this as a 2027 problem are miscalibrating the risk.
For background, see our evergreen guide on the Section 301 overcapacity investigation and the Section 301 China tariffs rates guide.
Bottom line
Seventy-six investigations, two dockets, one shared comment deadline of April 15, 2026, and hearings that start April 28. If your products originate in any of the 16 overcapacity economies, expect concrete tariff risk on your HTS codes. If your supply chain touches any of the 60 forced-labor economies — even through an allied country — expect enforcement risk regardless of tariff outcomes.
The last 72 hours before the comment deadline are the cheapest opportunity all year to put your own data on the record. After that, importers are reacting to what USTR already wrote down.