UK exporters could face additional US tariffs under a new forced-labour trade proposal that would tie market access more closely to supply-chain enforcement and modern slavery controls.
The US Trade Representative has proposed tariffs of up to 12.5% on imports from 60 economies after determining that trading partners had failed to curb trade in goods made with forced labour. The UK, European Union, Canada, and several other economies are listed among countries facing proposed additional duties of 10%.
The proposal was issued under a Section 301 unfair trade practices investigation. It follows the striking down of earlier emergency tariffs imposed by the Trump administration, leaving Washington to pursue alternative legal routes for its trade agenda.
The USTR has proposed 10% additional duties on imports from Canada, Ecuador, the European Union, Indonesia, Mexico, Pakistan, Argentina, Bangladesh, Cambodia, El Salvador, Guatemala, Malaysia, Taiwan, and Britain. It has proposed additional 12.5% duties on 45 other countries, including China, India, Nigeria, Japan, South Korea, Vietnam, Australia, and New Zealand.
Public comments on the proposal are due by 6 July, with a public hearing scheduled for 7 July. The tariff plan also contains a long list of proposed exemptions, including imports already subject to US national security tariffs, some North American trade deal-compliant goods, crude oil and petroleum products, rare earths, pharmaceuticals, some agricultural products, organic chemicals, and aircraft parts.
US Trade Representative Jamieson Greer said: “The failure of our most important trading partners to address the importation of goods made with forced labour is unacceptable,” adding that it created unfair competition for US workers.
The proposal has already drawn objections from affected trading partners. The European Commission said the tariffs were unjustified and reiterated its commitment to the trade deal agreed with Washington last year. The UK said it was in regular talks with the United States and was taking action to tackle forced labour, while adding that preferential access to US markets negotiated for UK businesses remained in place.
The dispute exposes a widening gap in how major markets approach forced-labour enforcement. The US has long had a border-enforcement model. Section 307 of the US Tariff Act of 1930 prohibits the importation of goods made wholly or in part with forced labour, convict labour, or indentured child labour, and gives customs authorities powers to detain, exclude, or seize goods suspected of being linked to forced labour.
The UK’s Modern Slavery Act 2015 is built differently. It requires companies to report publicly on steps taken to address slavery and human trafficking in their operations and supply chains, but it is mainly a transparency regime rather than a forced-labour import ban.
The EU has adopted a Forced Labour Regulation that will ban products made with forced labour from being sold in the EU market, whether imported or produced domestically. Those rules take effect on 14 December 2027. Germany and France also have corporate due-diligence regimes focused on human rights and supply-chain responsibilities, although their approaches do not operate in the same way as a customs import ban.
That difference creates a practical problem for UK companies exporting to the US. Modern slavery statements, supplier codes, contractual clauses, and audit processes may not be enough if US enforcement expects evidence capable of withstanding border scrutiny, product-level tracing, or challenge from customs authorities.
Procurement teams are likely to face the first wave of pressure. Companies selling into the US, or supplying larger exporters that do, may need stronger documentation on supplier origin, labour conditions, production sites, subcontracting, and corrective action. Exposure will be higher in sectors with complex upstream supply chains, including textiles, electronics, solar, food, automotive components, metals, and consumer goods.
The proposal also complicates ESG reporting. Many companies have treated modern slavery compliance as an annual disclosure exercise. The US approach turns the issue into a trade-exposure and shipment-risk question. If goods can be delayed, excluded, or priced with additional tariffs, forced-labour due diligence becomes directly connected to working capital, customer contracts, and route-to-market assumptions.
The exemption list may soften the near-term economic effect, but it also makes compliance more complex. Companies will need to understand whether their goods fall within exempted categories, whether components or inputs create exposure, and whether customers in the US are likely to demand additional assurances from suppliers.
Trade policy is increasingly being used to enforce social, environmental, and security objectives. Supply chains built primarily for cost, speed, and resilience are now being tested against labour standards, carbon exposure, sanctions, and geopolitical alignment.
The final tariff decision may change after consultation, but the direction is unlikely to disappear. Modern slavery controls are moving from disclosure to enforcement, and from reputational risk to trade risk. UK exporters with US exposure now have a narrow window to review whether their supply-chain evidence is strong enough for a more interventionist customs environment.
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