Michael Volkov examines USTR’s unprecedented Section 301 forced labor tariff proposal, analyzing how the Trump Administration is leveraging a decades-old trade statute to rebuild broad tariff coverage following the Supreme Court’s invalidation of IEEPA emergency tariffs in Learning Resources, Inc. v. Trump. Covering economies that account for an estimated 99.4% of U.S. imports, the proposal would impose 10% duties on 14 economies with partial forced labor import regimes—including Canada, Mexico, the EU, and the UK—and 12.5% duties on 46 economies with no meaningful forced labor prohibition, including China, Japan, Brazil, and South Korea, with all new duties stacked on top of existing tariffs. Michael details the critical July 6, 2026 comment deadline, outlines the compliance action items companies must execute now—supply chain exposure mapping, HTS-level Annex A exclusion analysis, UFLPA interaction assessment, and tariff stacking modeling—and explains why this proceeding represents both a trade enforcement initiative and a deliberate legal architecture strategy designed to produce the robust administrative record that emergency tariff authority lacked.