Tariff Watch: Section 301 Hearings, USMCA Review, and the Looming Section 122 Expiration

Welcome back to Tariff Watch from J.M. Rodgers Co. Each week, we break down the latest customs announcements, analyze who bears the brunt of the impact, and tell you how fellow supply chain leaders are reacting to the news.

Even though the first week of July was less about sudden changes and more about the normal administration of US trade policy, it may go down as one of the most pivotal moments of 2026. With several major public comment deadlines colliding and a huge temporary tariff inching toward its statutory expiration, the events of this week may determine how the rest of the year plays out. Here’s what you need to know:

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What’s New

• The USMCA Free Trade Commission began its formal review: On July 1, the Commission officially commenced its review of the Canada-United States-Mexico Agreement, which was triggered by the US’s decision not to renew the USMCA in its current form. Commission members will evaluate the trade pact’s effectiveness and will likely recommend changes that could have a major impact on North American trade for years to come.
• The USTR’s public comment period closes this week: The United States Trade Representative’s public comment period on potential Section 301 tariffs closes on Monday, July 6. The USTR has proposed duties ranging from 10% to 12.5% on 60 economies for alleged shortfalls in enforcing anti-forced-labor laws. Following the close of the docket, the USTR will launch public hearings on the matter starting Tuesday, July 7.
• The US-China Board of Trade deadline approaches: Importers have until Friday, July 10, to submit comments to the USTR about Chinese-origin products that should receive tariff relief. Up to $30 billion in “non-sensitive” imports from China could see duty reductions under the newly chartered US-China Board of Trade, which will consider the comments collected by the USTR.

Who’s Impacted

This week’s news stories have big implications for the future of:

• Global importers and sourcing teams: The sheer scale of the proposed Section 301 forced-labor tariffs means that companies importing from nearly any major US trading partner could be affected. This week’s hearings will determine whether new tariffs of 10% to 12.5% are imposed on more than 99% of US imports.
• North American supply chains: Businesses that rely on the USMCA for trade should closely watch for the results of the Free Trade Commission’s review. Any proposed adjustments to rules of origin or labor enforcement could create a ripple effect felt across the continent’s supply chains.
• Importers of Chinese goods: The US.-China Board of Trade represents a rare opportunity for companies importing non-sensitive Chinese products to secure substantial long-term tariff relief.

What We’re Seeing

Rather than waiting for final rulings, proactive supply chain leaders are acting now to protect their profit margins:

• Importers are finalizing US-China Board of Trade comments: With the July 10 deadline just days away, we are seeing trade compliance teams working closely with legal counsel to build robust economic cases. They hope to prove that their Chinese-origin imports pose no national security risks and warrant inclusion in the $30 billion tariff relief package.
• Businesses prepare for the end of Section 122: Because the Section 122 global surcharge is legally mandated to expire on July 24, business leaders are mapping out life after the 10% tariff. Many are forecasting how an immediate shift from the temporary Section 122 surcharge to the permanent Section 301 forced labor tariffs will affect their landed costs in Q3 and Q4.
• Companies demand specialized exclusions: In their final submissions before the Section 301 forced labor deadline, numerous businesses lobbied hard for targeted exclusions for textile goods, apparel, and other imports that have complex global sourcing footprints.

What We’re Monitoring

This week’s stories will continue to develop over the next few months. Here’s what we’ll be watching:

• The USTR forced labor hearings: We’ll be keeping a close eye on the public hearings kicking off on July 7. We will analyze the testimonies to gauge the administration’s willingness to grant product exclusions, adjust the proposed 10% to 12.5% duty rates, or delay the implementation date.
• The July 24 Section 122 expiration: We’re just weeks away from the statutory 150-day expiration of the Section 122 tariffs. We’ll be looking for clues about whether the administration will allow the tariffs to expire quietly or pressure Congress for an extension. If the admin immediately imposes Section 301 forced-labor tariffs, this could be the end of the Section 122 story for now.
• The outcome of the USMCA review: As the Free Trade Commission continues its review, we’ll be on the lookout for changes to automotive origin requirements, digital trade rules, or cross-border labor enforcement mechanisms that could disrupt the status quo of North American trade.

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Sources

• United States Declines to Extend Agreement, Triggering Annual Review, White & Case
• Public Hearings on the Section 301 Investigations, USTR.gov
• US-China Relations in the Trump 2.0 Era, China Briefing