According to VCCI, the US is Vietnam's largest export market, and the new policy moves from the US place the export business community in a serious trade risk situation. Accordingly, businesses need to closely review the entire supply chain.
New US Tariff Proposal
On June 2, 2026, the Office of the United States Trade Representative (USTR) published the investigation conclusions and proposed remedial measures against 60 economies regarding the issuance and enforcement of bans on importing goods produced with forced labor.
In this list, Vietnam was identified by the US investigative body as one of the economies directly affected by the proposed trade sanctions.
The Vietnam Chamber of Commerce and Industry (VCCI) stated that, from the perspective of classification, the USTR placed Vietnam in the group of 54 economies concluded as "not issuing and not effectively enforcing" a ban on importing goods made with forced labor.
"This is the group that the USTR assessed as having a significantly higher level of deficiency in practical measures compared to the six economies only concluded as 'not effectively enforcing,' including Canada, Ecuador, the EU, Indonesia, Mexico, and Pakistan, which already have a ban or have commitments under a Trade Agreement with the US," VCCI emphasized.
Although the investigation report noted Vietnam's explanatory position on April 14, 2026, regarding the issuance and implementation of measures to prevent, detect, and eliminate forced labor, the US side still affirmed that, at the present time, Vietnam has not established a direct legal ban on the import of such goods.
On that basis, Vietnam's actions, policies, and practices were determined by the partner to be unreasonable and to constitute a burden or restriction on US commerce, creating a legal basis for the application of sanctions under Section 301(b) of the Trade Act of 1974.
Regarding the proposed measures, the USTR proposes to impose additional ad valorem tariffs on all products from the investigated economies, except for items excluded in Appendix A of the notice.
The punitive tariff structure is divided into two tiers: a 10% tariff rate applies to economies that have enacted an import ban, have established a commitment through a reciprocal Trade Agreement, or have adopted a partial control mechanism; a 12.5% tariff rate applies broadly to all remaining economies, including Vietnam.
At the same time, the US side plans to implement a special mechanism for textiles and garments, allowing a certain volume of clothing and textile products to benefit from a preferential Section 301 tariff rate based on the proportion of raw cotton and textile fiber inputs imported back from the US.
In terms of legal nature, all the above content is currently only at the draft proposal stage in the public comment process of the Section 301 Committee and does not constitute a final and enforceable decision.
The USTR has set the deadline for submitting speaking registrations with content summaries as June 22, 2026, and the deadline for written comments as July 6, 2026, before officially holding public hearings on July 7, 2026.
The Vietnamese government's active participation in previous and upcoming consultations with the US side shows that Vietnam maintains a strategic dialogue space to express its views and request adjustments before the US tariff measures are formally enacted.
Serious Risk for Export Business Community
Under the macroeconomic impact, the new policy moves from the US place the export business community in a serious trade risk situation.
VCCI believes that, as the US continues to be Vietnam's largest export market, the imposition of a broad additional 12.5% tariff will directly affect the competitiveness and profit margins of key industries including textiles, footwear, wood products, electronics, and seafood.
The level of systemic risk increases further when the partner's investigation report directly names two core, highly sensitive supply chains—raw cotton and polysilicon input for solar panel production technology—in its analysis of evasion of sanctions control measures.
Given the serious situation, a thorough review of the entire supply chain and the implementation of a traceability process for input materials to completely eliminate any factors related to forced labor allegations has become an urgent requirement for businesses.
From a policy perspective, the tiered punitive structure of the US suggests a noteworthy direction for resolution: since the 10% rate is reserved for economies that have established an import ban or have committed to this issue through a reciprocal Trade Agreement, Vietnam proactively studying and perfecting the legal framework to ban the import of goods made with forced labor, or including this content in the bilateral trade negotiation agenda, would be a basis for lobbying the US to move Vietnam from the 12.5% group to the 10% group.
"In the short term, from now until July 6, 2026, is a very important period for state management agencies, industry associations, and the export business community to proactively draft and submit written comments, register to attend public hearings, in order to lobby the partner to expand the list of excluded goods in Appendix A for key export items, and at the same time clarify the actual forced labor prevention and combat measures that Vietnam is striving to implement."
According to VCCI
