US Section 301 Tariffs Prompt SA Forced Labour Regulation Notice

Posted 27 July 2026 Written by Acts Online

Brought to you by SAnews: The Department of Trade, Industry and Competition (“DTIC”) has announced plans to publish a notice in the Government Gazette requesting public comments on its intention to issue regulations prohibiting goods produced in whole or in part using forced labour and child labour.

The regulatory step follows the United States Trade Representative (“USTR”) imposing a 12.5% tariff on South African exports pursuant to Section 301 investigations into trade practices and forced labour import enforcement across 60 economies. South Africa is listed among 41 economies cited by the USTR for lacking specific statutory prohibitions on importing forced-labour-produced goods. A lower 10% rate was assigned to 19 economies with established import bans.

Certain export product categories remain exempt or excluded from the Section 301 duties:

  • Section 232 Exclusions: Products already subject to Section 232 tariffs—including automobiles, automotive components, steel, and aluminium—are exempted from Section 301 tariffs.
  • Federal Register Exemptions: Specific items listed under Annex I and Annex II of the US Federal Register, including macadamia nuts, oranges, limes, tea, spices, seeds, cane sugar, citrus juices, syrups, chemicals, critical minerals, platinum-group metals, isotopes, civil aircraft components, and pharmaceuticals.

Minister of Trade, Industry and Competition Parks Tau confirmed that government will proceed with gazetting draft regulations to establish forced labour prohibitions while continuing bilateral engagements with the USTR seeking tariff reductions or exemptions.

What this means for you, your business, or your clients

  • For yourself: No direct individual obligations; compliance exposure is channelled through corporate supply chain governance and international trade requirements.
  • For your business: Exporters to the United States must assess their tariff classifications against Annex I and Annex II of the US Federal Register to determine whether their goods are subject to the 12.5% tariff or qualify for specific product exclusions.
  • For your clients: Manufacturers and commercial importers operating in South Africa should prepare supply chain audit procedures and origin verification processes ahead of the DTIC’s forthcoming draft regulations on forced and child labour prohibitions.

Originally published at https://www.sanews.gov.za/south-africa/sa-continue-engagement-us-tariffs


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