Current Section 301 Investigations are Opportunities to Speak out on PF Restrictions in Trade Remedy Tariffs – March 31, 2026

Please Note: When evaluating tariff announcements, carefully review each Executive Order, the corresponding Federal Register Notices, and CSMS messages in detail. Consult with your trade attorney or advisor to understand how these measures specifically impact your U.S. FTZ operations.

On the evening of March 11, the Office of the U.S. Trade Representative (“USTR”) announced the initiation of several Section 301 investigations related to structural excess capacity and production.  Public comments will be collected starting March 17 until April 15, followed by a public hearing on May 5.

The Federal Register notice can be found HERE; docket for submitting public comments HERE; and docket for requests to testify HERE.

On March 12, USTR also announced the initiation of sixty new Section 301 investigations into whether the failure of America’s largest trading partners to effectively enforce measures banning goods made with forced labor is unreasonable or discriminatory and burdens or restricts U.S. commerce.  USTR is requesting public comments and will hold a public hearing on April 28.  Comments and requests to testify must be submitted by April 15.

The pre-publication version of the Federal Register notice is available HERE; the docket for submitting comments will be available HERE; and the docket to submit requests to testify at the public hearing will be available HERE.

NAFTZ plans to request to testify in both hearings and, where practicable, submit written comments; our testimony will focus on the impact the restrictions placed on U.S. FTZ admissions have had on U.S. manufacturing and distribution.

We encourage all of our members (and non-members) to submit comments, both on the subject of the investigation, either excess capacity, forced labor, or both as it impacts your business  Please also include how the requirement to admit all subject goods in Privileged Foreign status is impacting your business and encourage USTR to recommend no such restrictions be included in any Executive action taken as a result of the investigations.

Contact info@naftz.org for further information or questions.