The Office of the United States Trade Representative (USTR) has identified Nigeria among 60 global economies in a new Section 301 investigation concerning the enforcement of prohibitions against goods produced with forced labour. This investigation, concluded on June 2, 2026, has led to a proposal for additional tariffs on imports from the affected countries.

What the Proposal Entails

Following an investigation launched on March 12, 2026, the USTR determined that the failure of these economies to effectively police and prohibit the importation of goods made with forced labour constitutes an "unreasonable" practice that burdens U.S. commerce.

  • Proposed Tariff Rates: The USTR has proposed two tiers of additional duties:

    • 12.5% Additional Duty: Proposed for 46 economies including Nigeria that have not implemented or effectively enforced forced labour import prohibitions.

    • 10% Additional Duty: Proposed for 14 economies that have existing prohibitions or have made specific commitments to enforce them.

  • Status of the Proposal: These tariffs are currently proposals and have not yet taken effect. The USTR has initiated a public consultation process to allow stakeholders to provide feedback.

Next Steps and Consultation

The USTR is inviting public comments and testimony to review the scope and impact of the proposed duties:

  • Public Comment Period: Deadline for written submissions is July 6, 2026.

  • Public Hearings: Scheduled to begin on July 7, 2026.

  • Exclusions: The proposal includes certain product-specific exclusions (listed in Annex A of the USTR notice) and carves out specific goods, such as those covered by existing Section 232 tariffs or certain USMCA-compliant products.

Implications for Nigeria

If the 12.5% tariff is finalized, it would be applied as an additional duty. The USTR argues that such measures are necessary to create a "level playing field" for American workers and to pressure trading partners to strengthen their labour supply chain oversight. Nigerian exporters and stakeholders are encouraged to monitor the USTR's upcoming hearings and engage in the public comment process to address the specific findings regarding Nigeria's current labour enforcement frameworks.