The US administration has imposed broad new tariffs under Section 301 linked to forced labor, according to The National Law Review, while the temporary Section 122 surcharge on imports has expired. The two moves, landing together, redraw the duty calculation that apparel, footwear and textile sourcing managers apply to every US-bound purchase order.

The shift matters commercially for two reasons. First, Section 301 tariffs are a durable instrument: unlike the Section 122 surcharge, which carries a statutory time limit of roughly 150 days without congressional extension, Section 301 measures can stay in force for years and can be expanded through follow-up review processes. Second, tying the new duties to forced labor connects tariff exposure directly to traceability and compliance programs, not just to country of origin.

What changes for importers?

The headline facts, as reported, are straightforward:

• New, broad Section 301 tariffs are now in place, framed around forced-labor concerns.
• The Section 122 surcharge has expired, removing that temporary add-on from the duty stack.

For sourcing teams, the practical question is how the two effects net out on any given lane. An expiring surcharge cuts landed cost; a new or expanded Section 301 tariff raises it. The net position will differ by product category, origin country and — in this case — by forced-labor risk profile of the supply chain behind the goods.

The National Law Review's framing signals that the forced-labor linkage is the operative logic of the new measures. That aligns Section 301 tariff policy with the existing Uyghur Forced Labor Prevention Act enforcement regime, under which CBP already detains goods it suspects involve inputs from the Xinjiang region. Importers now face two overlapping exposure channels: detention and exclusion on the one hand, and duty liability on the other.

Who pays and what to verify now

Tariff changes of this kind flow through the supply chain on the terms written into existing vendor agreements. Brands with FOB or FCA terms absorb the duty at entry; those with DDP terms push it to the vendor, at least until contracts are renegotiated. Sourcing directors should audit open POs and in-transit shipments to determine which tariff regime — the expired surcharge or the new Section 301 measure — applies at the date of entry, since the effective-date boundary will decide real money on containers already on the water.

Compliance teams should treat the new tariffs as a prompt to re-verify supplier maps. Forced-labor-linked tariff exposure puts a premium on:

• Documented, farm-to-factory traceability for cotton and other high-risk inputs.
• Third-party audits and certifications that hold up under CBP review.
• Contract clauses allocating tariff-increase risk between brand and vendor.

Confirmed versus prospective

The expiration of the Section 122 surcharge and the imposition of the Section 301 forced-labor tariffs are the confirmed facts reported by The National Law Review. The publication's analysis does not, on the available headline, enumerate specific tariff rates, product lists or effective dates — details sourcing executives will need before recalculating cost sheets. Legal counsel and customs brokers should confirm the Federal Register notice specifics before any landed-cost model is updated.

What is clear is direction: US tariff policy is consolidating around forced labor as a enforcement hook, which makes supply-chain transparency a cost variable, not just a reputational one. Importers should expect follow-on reviews and possible list expansions under the Section 301 framework in the months ahead.