ESG Enforcement Tracker

On 12 March 2026, the United States Trade Representative (USTR) launched investigations into 60 economies, under Section 301(b) of the Trade Act of 1974. The probe will determine whether acts, policies, and practices of each of these economies related to the failure to impose and effectively enforce a ban on the importation of goods produced with forced labour are unreasonable or discriminatory and burden or restrict US commerce.

Section 301 of the Trade Act of 1974 is said to address unfair foreign practices affecting US commerce. Section 301 may be used to respond to unjustifiable, unreasonable, or discriminatory foreign government practices that burden or restrict US commerce. Under Section 302(b) of the Trade Act, the USTR may self-initiate an investigation under Section 301.

After considering the advice of the inter-agency Section 301 Committee, the USTR initiated the investigations. The USTR must seek consultations with the economies whose acts, policies, or practices are under investigation. The USTR will hold hearings in connection with these investigations on 28 April 2026. Interested persons are requested to submit written comments and requests to appear at the hearing, along with a summary of the testimony, by 15 April 2026.

A list of the economies subject to the investigations can be found here.