More than 1,500 stakeholders, including Ford, Nestlé, Tesla and Whirlpool, have filed comments asking USTR to exclude their products from the proposed Section 301 tariffs. The plan would impose forced labor duties of 10% on 14 economies and 12.5% on 46 more. These duties would stack on top of existing tariffs.
For importers sourcing from one of the 60 flagged economies without an existing exemption, this filing round decides landed cost. The written comment period and USITC hearings have ended, so the post-hearing rebuttal period is the final chance to secure a product-specific exemption before USTR finalizes the list.
Who filed what: The requests split into two groups, with some seeking product-specific exemptions and others asking for exemptions based on importer status. Here are some of the key requests:
Mars, McCormick: Ingredients like palm oil and spices with “no domestic availability,” per the filings, on climate and geography grounds
Ford, Tesla: Critical manufacturing inputs, with Tesla arguing they “cannot yet be sourced at the scale and quality necessary” to sustain US production
GE Appliances, Tractor Supply: Manufacturing equipment and “essential rural goods for which there is no domestic capacity”
Whirlpool, Bissell: A carve-out for CTPAT-compliant importers, plus a Bissell ask to move Vietnam into the lower 10% bracket
USTR's stance: The agency opened the docket after finding that 60 economies had failed to block goods made with forced labor. Ambassador Jamieson Greer called this failure by major trading partners “unacceptable.”
What's next: July 24 carries a double deadline. The Section 122 surcharge expires that day. USTR is also widely expected to finalize the Section 301 list on the same day. This would leave no gap between the old surcharge lapsing and the new tariff taking effect. The two duties stack rather than replace one another.
