
Policy & Trade
Forced-labor tariffs hit 60 trading partners, and they stack
A new tariff regime covering most of what the United States imports took effect at 12:01 a.m. Eastern on July 24. Section 301 forced-labor tariffs of 10% or 12.5% now apply to goods from 60 designated trading partners, according to an analysis from Troutman Pepper Locke. For furniture importers the headline number is the one on Vietnam and China: both sit in the 12.5% tier.
The legal route matters for understanding why this exists. The action follows the Supreme Court's February 2026 ruling that the International Emergency Economic Powers Act does not authorize tariffs, which eliminated the administration's prior program. Section 301 of the Trade Act of 1974 provides a different basis, and USTR built the case on forced labor: its investigations concluded that 54 trading partners had imposed no forced-labor import prohibition at all, while six others, Canada, the EU, Ecuador, Indonesia, Mexico and Pakistan, have prohibitions but do not enforce them effectively.
Two tiers, and where sourcing countries land
The 10% rate applies to 17 economies that either maintain forced-labor prohibitions or committed to adopt them after June 5, 2026: Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, and the United Kingdom. The 12.5% rate covers 38 economies lacking such prohibitions, China and Vietnam among them. A third group is capped at most-favored-nation rates: the EU and Taiwan at 10%, Japan, South Korea and Switzerland at 12.5%.
For furniture sourcing that produces an uneven map. Vietnam, which absorbed enormous volume as brands moved production out of China, now carries the same 12.5% as China itself. India, Malaysia and Indonesia sit at 10%, a 2.5-point advantage that is small in isolation but real at container scale. USTR has also signaled textile and apparel tariff-rate quotas for Bangladesh, Cambodia, Indonesia and Malaysia, allowing set volumes in duty free, with the standard 10% applying until those are implemented.
Stacking is the part that changes landed cost
These duties stack on top of all other applicable tariffs, including existing Section 301 China lists 1 through 4A, Section 232 duties, Section 201 safeguards, and antidumping and countervailing duties. There is one significant carve-out running the other way: goods already subject to Section 232 tariffs are fully exempt from the forced-labor tariff. Customs guidance sequences the reporting, with the forced-labor tariff reported first among the trade-remedy Chapter 99 codes, ahead of Section 122, Section 232 and Section 201.
Exemptions are broader than the initial proposal. USTR expanded the final list by 471 HTSUS subheadings after public comment, covering raw materials, supply-chain-critical goods, and products that cannot be sourced domestically in sufficient volume, per a client advisory from C.H. Robinson. Universal exemptions include USMCA-qualified goods from Canada and Mexico, CAFTA-DR qualifying textiles, pharmaceuticals, civil aircraft, informational materials and most Chapter 98 entries. The in-transit relief was narrow and is now expired: it applied only to ocean freight loaded before July 24 and entered before July 28, with air, truck and rail excluded entirely.
Why switching origin no longer solves it
Why it matters: Most Bison-relevant furniture is imported, so a duty that applies to nearly every sourcing country at once cannot be engineered around by switching origin the way a single-country tariff can. The 2.5-point gap between the tiers is the only lever origin gives you, and it is thin against the cost of requalifying a supply base. This lands on top of the 25% furniture-specific tariffs that held in May after larger increases were delayed a year, and it is the regime importers were front-loading against when transpacific container rates hit a 22-month high in June. That front-loaded inventory is now the last cost-advantaged stock in the channel.
What it means for our partners: Landed-cost models built before July 24 understate duty on nearly every imported line, and the exemption list is long enough that it is worth checking by HTSUS subheading rather than assuming coverage. We are working through which products fall inside the expanded exemptions, and treating the stacking sequence as a compliance question for brokers rather than something to resolve at the pricing layer.
Source: Troutman Pepper Locke


