According to VCCI, new policy moves from the United States have placed the Vietnamese export business community under severe trade compliance risks.

On June 2, 2026 (Washington time), the Office of the United States Trade Representative (USTR) announced its investigation findings regarding 60 nations under review pursuant to Section 301 of the Trade Act of 1974. Accordingly, the USTR has proposed implementing additional ad valorem tariffs on all products from the investigated economies, including Vietnam.

The USTR categorized Vietnam into a group of 54 economies determined to have "failed to impose and effectively enforce" a legal prohibition on the importation of goods manufactured wholly or in part with forced labor. Meanwhile, six other economies were concluded to have merely "failed to effectively enforce" such a prohibition, including Canada, Ecuador, the European Union, Indonesia, Mexico, and Pakistan—which already maintain domestic bans or have established explicit commitments within reciprocal trade agreements with the US.

Although the investigation report acknowledged the explanatory stance previously provided by the Vietnamese side, the US side asserted that at the present time, our country has not yet established a direct, comprehensive statutory ban against the importation of such forced labor goods. On that basis, the acts, policies, and practices of Vietnam were determined to be unreasonable, burdensome, or restrictive to US commerce, establishing the legal foundation to initiate responsive sanctions under Section 301(b) of the Trade Act of 1974.

Regarding the responsive actions, the USTR proposed imposing additional ad valorem duties on all products from the investigated economies, except for certain commodities exempted under Appendix A of the notice.

The punitive tariff structure is partitioned into two distinct tiers: Tier 1 (10% tariff rate): Applicable to economies that have already adopted full or partial forced labor import prohibitions, or have established commitments via reciprocal trade agreements. Tier 2 (12.5% tariff rate): Applicable to Vietnam and the remaining economies.

Concurrently, the US side plans to roll out a special mechanism for textiles and apparel, allowing a certain volume of apparel and textile imports to benefit from preferential Section 301 tariff rates based on the proportion of raw cotton and textile yarn inputs re-imported directly from the US.

Faced with this development, the Vietnam Chamber of Commerce and Industry (VCCI) noted that all the aforementioned contents currently remain at the proposal stage within the public comment process of the Section 301 Committee, and do not yet constitute a final, legally binding decision. However, these new policy shifts from the US have placed the export business community in a state of severe trade risk.

Imposing an additional 12.5% tariff on a broad scale will directly erode the competitiveness and profit margins of Vietnam's flagship manufacturing and export industries, including textiles, footwear, wooden furniture, electronics, and seafood.

“The level of systemic risk intensifies as the partner's investigation report directly singles out two highly sensitive core supply chains—raw cotton and polysilicon inputs for solar panel manufacturing technology—within its analysis of acts aimed at circumventing trade enforcement controls,” VCCI informed.

According to VCCI, given this critical context, an urgent mandate for enterprises is to rigorously review their entire supply chains and deploy strict raw material origin traceability processes to completely eliminate any factors linked to allegations of forced labor.

From a policy perspective, if Vietnam proactively researches and perfects its statutory framework to ban imports produced by forced labor, or integrates this agenda into bilateral trade negotiations, it will establish a solid foundation to lobby the US to move our country from the 12.5% tier down to the 10% tier.

According to VCCI, from now until July 6, 2026, is a vital phase for state management agencies, industry associations, and the export business community to proactively construct and submit written comments, as well as register for the public hearings. This collective effort aims to lobby the partner to expand the list of exempted commodities in Appendix A for key export items, while clarifying the actual anti-forced labor measures that Vietnam is diligently implementing.

The USTR has fixed specific timelines for the consultation process: June 22, 2026: Deadline to submit requests to appear at the public hearings accompanied by a testimony summary. July 6, 2026: Deadline to submit written comments. July 7, 2026: Official convening of public hearings by the Section 301 Committee.

According to the Vietnam Association of Seafood Exporters and Producers (VASEP), specific information regarding whether seafood commodities fall under the exemptions is not yet available. However, this new US move underscores a rising global trend toward demanding origin traceability, supply chain transparency, and compliance with international labor standards.

"VASEP will continue to gather and synthesize member feedback on the impacts of the proposed measure, serving as a foundation to construct a comprehensive comment brief to be submitted to the USTR within the aforementioned public comment window," the Association announced.

According to data from the General Statistics Office, during the first 5 months of 2026, the US remained Vietnam's largest export market, with a turnover reaching 69.6 billion USD. Vietnam recorded a trade surplus of 60.4 billion USD with the US, a 21.1% surge compared to the same period last year.

Source: Vnbusiness