As previously shared in email updates to the full Toy Association membership on March 12 and 13, the Office of the U.S. Trade Representative (USTR) has launched two new Section 301 investigations examining structural excess manufacturing capacity and the use of forced labor in global supply chains. These actions could potentially lead to additional trade measures, including tariffs.
Structural Excess Manufacturing Capacity (announced March 11, 2026)
The first investigation will examine whether certain foreign government policies promote manufacturing levels that exceed global demand, which can flood markets and negatively impact U.S. manufacturing.
- The investigation focuses on the following economies: China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India.
- USTR will evaluate whether policies in these economies contribute to structural excess manufacturing capacity that distorts global markets.
- Ambassador Jamieson Greer noted the investigation is part of the Administration’s broader effort to reshore critical supply chains.
- Written comments are due by April 15, with public hearings expected on or about May 5.
Forced Labor in Global Supply Chains (announced March 12, 2026)
The second investigation will review whether failures by foreign governments to prevent trade in goods produced with forced labor negatively affect U.S. commerce and American companies competing under lawful labor standards.
- USTR identified 60 of the largest U.S. trading partners as part of this review, including Brazil, China, Hong Kong, India, Indonesia, Mexico, and Vietnam, among others.
- The investigation will examine whether inadequate enforcement against forced labor results in artificially low-cost imports entering global markets.
- In announcing the investigation, Ambassador Greer stated the review will determine whether governments have taken sufficient steps to prohibit the importation of goods produced with forced labor and how these practices impact U.S. workers and businesses.
- Written comments are due by April 16, with public hearings expected between April 28 and May 1.
The Toy Association is currently gathering input from member companies to inform potential industry comments to USTR and will continue to keep members informed as the investigations move forward. Members may contact Maria Sierra, vice president of government affairs at The Toy Association, with any questions or to provide input for the comments.