The European Union’s fragile trade understanding with the United States has come under renewed pressure after Washington proposed additional tariffs on imports from 60 economies, including the EU, citing alleged failures to prevent goods made with forced labour from entering global supply chains.
The proposal, issued by the Office of the United States Trade Representative, follows a Section 301 investigation launched in March. The USTR said it had found that a large number of trading partners had failed to impose and effectively enforce prohibitions on the import of goods produced with forced labour.
Under the proposed action, the United States would impose additional duties of 10 per cent on imports from the European Union, the United Kingdom, Canada, Mexico and several other economies. A higher rate of 12.5 per cent would apply to countries including China, India, Japan and South Korea.
The timing is politically sensitive. The EU is still working to complete implementation of its trade commitments under an agreement reached with Washington last year. President Donald Trump had given Brussels until 4 July to implement the deal, warning that tariffs on EU goods, including cars, could otherwise rise to higher levels. EU governments have since moved to approve legislation cutting import duties on US goods, but the European Parliament must still complete its part of the process.
The new forced labour proposal risks complicating that timetable. It introduces a second tariff track just as Brussels is trying to avoid escalation over the existing EU-US trade arrangement. The USTR’s proposal is also subject to a public comment period until 6 July, with a hearing scheduled for 7 July, meaning the issue may run directly into the final phase of the wider trade dispute.
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For Brussels, the US argument is difficult to separate from the broader tariff strategy pursued by the Trump administration. Washington is presenting the measure as a labour and trade-enforcement action. European officials are likely to see it as another attempt to retain leverage after several legal setbacks to earlier tariff measures.
Bernd Lange, chair of the European Parliament’s International Trade Committee, said additional tariffs on EU goods would be unacceptable and argued that any duties above the agreed 15 per cent ceiling under the existing trade arrangement would breach the political understanding between the two sides. He also rejected the suggestion that the EU is failing to address forced labour in supply chains.
The EU adopted its own Forced Labour Regulation in 2024. The measure prohibits products made with forced labour from being placed on the EU market or exported from the EU. However, the main provisions will only begin to apply from 14 December 2027, according to the European Commission.
That delay gives Washington an opening to argue that the EU’s framework is not yet enforceable at the border. The US already operates more direct import controls through existing customs law and the Uyghur Forced Labor Prevention Act, which has been used to block goods linked to Xinjiang. Europe’s approach has so far relied more heavily on corporate due diligence, transparency obligations and delayed implementation of market-access bans.
The dispute therefore exposes a real difference in enforcement models. The United States has built a system centred on border exclusions and customs enforcement. The EU has chosen a broader internal-market model, intended to apply across all products and sectors but only after national authorities and Commission systems are in place.
For European companies, the immediate problem is uncertainty. Exporters already face the possibility of higher tariffs if the July deadline is missed. They now also face the prospect of forced labour-related duties even if the broader trade deal is implemented. Compliance departments will have to manage overlapping legal regimes, including EU due diligence rules, the forthcoming forced labour ban, US customs enforcement and sector-specific supply-chain requirements.
The proposed tariffs also raise questions about proportionality. The USTR has grouped the EU with dozens of other economies, despite the bloc having adopted legislation that will eventually establish a full product ban. That may strengthen the argument in Brussels that Washington is using forced labour concerns as a trade instrument rather than as a targeted enforcement measure.
At the same time, the EU cannot dismiss the issue entirely. Forced labour risks remain present in global supply chains, including in sectors such as textiles, solar components, agriculture, electronics, minerals and seafood. The problem for Brussels is that its strongest legal response is still more than 18 months away from full application.
The US move is therefore more than a technical tariff proposal. It creates a new point of friction in transatlantic trade, tests the credibility of the EU’s forced labour regime before it has entered into force, and gives Washington another mechanism to apply pressure before the 4 July trade deadline.
Unless the two sides find a way to separate the forced labour investigation from the broader tariff deal, the issue could become another obstacle to stabilising EU-US economic relations. For businesses, the message is already clear: forced labour compliance is no longer only a human rights or due diligence matter. It has become a direct tariff risk.
