The Office of the United States Trade Representative determined on June 2 that 60 economies, Cambodia among them, have failed to impose and effectively enforce a prohibition on importing goods produced with forced labor, and proposed additional duties on their products under Section 301 of the Trade Act of 1974. The 60 are the largest sources of goods entering the United States, together accounting for 99.4 percent of its imports. For Cambodia the proposed rate is 10 percent, the lower of the two figures in the action, with 12.5 percent set for most of the rest.
Ambassador Jamieson Greer tied the finding to competition, stating that the failure to keep forced-labor goods out of partners’ markets leaves American workers, in his words, “forced to compete globally on an unlevel playing field.” USTR found the failure unreasonable on four grounds: that it undermines the aim of eliminating forced labor, lets firms using forced labor undercut those that do not, erodes the profits of compliant producers, and contributes to the circumvention of existing import bans.
USTR built the record over nearly three months. It opened the investigations on March 12, requested consultations with each economy, took more than 450 written comments, and heard close to 60 witnesses at hearings the Section 301 Committee held on April 28 and 29. Its report grounds the burden on United States commerce in forced-labor goods competing against American producers in both export markets and the home market, and runs case studies on polysilicon and cotton entering through third countries. The proposed duties are a first step; an affirmative action would let USTR move from the determination to tariffs the President can adjust by country.
The findings address whether each economy legally bars forced-labor goods from entering its own market, not the labor conditions of the goods those economies export. USTR placed Cambodia in the 10 percent group on the strength of the forced-labor commitment it entered in its October 2025 Agreement on Reciprocal Trade with Washington, grouping it with Argentina, Bangladesh, Ecuador, El Salvador, Guatemala, Indonesia, Malaysia and Taiwan, which made comparable commitments. Economies that already maintain an import prohibition, among them Canada, the European Union and Mexico, drew the same 10 percent rate, and all others were set at 12.5 percent.
USTR separated the commitment from a law in force. The notice records that a future commitment is “distinct from forbidding legally the importation of forced labor goods, and effectively enforcing such prohibition,” and that the duty an economy faces turns on whether it has made one. Cambodia’s agreement, signed in Kuala Lumpur on October 26, commits it to “adopt and effectively implement a prohibition on the importation” of goods produced with forced labor, and to act on United States determinations against named entities under Section 307 of the Tariff Act of 1930. The June 2 finding holds that the prohibition is not yet carried into enforced law.
The 54 economies USTR placed in the failed-to-impose category include Australia, Japan, New Zealand, Norway, South Korea, Switzerland and the United Kingdom. The finding turns on a feature of customs law most of them share, the absence of a statutory bar on forced-labor imports matching the one the United States has enforced under Section 307 for nearly a century. The six economies set apart, Canada, Ecuador, the European Union, Indonesia, Mexico and Pakistan, hold such a bar but were found to have left it unenforced, several under their USMCA obligations.
The investigations reach the United States’ 60 largest suppliers, a near-complete map of its import sources, and put the same question to each: whether a country’s law turns away forced-labor goods at the border, rather than what its factories produce. For Cambodia, the answer recorded on June 2 is a commitment in its trade agreement that the determination treats as not yet law.
The action follows the Supreme Court’s February 20 ruling that the International Emergency Economic Powers Act does not authorize tariffs, which removed the legal footing for the reciprocal duties imposed in 2025. The administration put a temporary 10 percent global surcharge in place under Section 122 of the Trade Act, an authority capped at 15 percent and 150 days, while USTR built the Section 301 cases that can carry country-specific tariffs without those limits. Section 301 duties carry no statutory ceiling or expiry, so an affirmative outcome could hold Cambodia’s rate at 10 percent on a durable basis, where the Section 122 surcharge cannot. A parallel Section 301 investigation into manufacturing overcapacity, opened March 11, names Cambodia among 16 economies.
Cambodia’s October agreement records its elimination of tariffs on all United States industrial and agricultural goods, a step Phnom Penh has already taken, and the 19 percent reciprocal rate the United States set in return, a figure that rested on the executive order the Supreme Court ruling unsettled. The agreement also acknowledges Cambodia’s standing as a least developed country and sets a five-year deadline to digitize border processing for United States goods. The proposed 10 percent forced-labor duty is an additional charge on a United States tariff baseline still being rebuilt.
The proposed duties would reach all products of the named economies except those in Annex A, which exempts goods already under Section 232 national-security tariffs, raw materials, a long list of agricultural products from beef to fresh produce, and items the United States cannot readily source at home. The annex also carves out USMCA-compliant goods of Canada and Mexico and duty-free textiles from the Central American CAFTA-DR partners. Apparel, footwear and travel goods do not fall under any of these exemptions. A separate textile mechanism would admit a volume of apparel and textile imports at a reduced rate, set in one part by the United States textile inputs a partner buys and in another by the United States cotton it imports, with the qualifying volumes left undefined in the notice.
Implementing and enforcing the prohibition it pledged would move Cambodia out of the category the determination penalizes, and the comment process gives Phnom Penh a documented channel to contest the proposed rate before USTR sets it. USTR kept that record open into July, with written comments due July 6 and requests to appear due June 22, ahead of a July 7 hearing. Cambodia took part in the government-to-government consultations USTR opened on March 12.
Neither the Ministry of Commerce, led by Cham Nimul, nor the Ministry of Foreign Affairs and International Cooperation, led by Prak Sokhonn, had issued a public response to the determination as of June 3.
USTR set Cambodia’s proposed rate below the 12.5 percent default on the strength of the forced-labor commitment in the Kuala Lumpur agreement, which the determination treats as a promise not yet carried into enforced law.