The Section 301 investigations allege excess manufacturing capacity that aims to burden or restrict U.S. commerce.
Key Points
- USTR initiates 16 Section 301 investigations (March 11, 2026) targeting excess manufacturing capacity in China, EU, Japan, India, Mexico, Korea, and 10 other economies.
- Sectors under investigation include semiconductors, steel, aluminum, automobiles, batteries, chemicals, electronics, solar modules, ships, robotics, and other manufactured goods.
- Section 301 findings of "unreasonable or discriminatory" trade practices could result in new tariffs, import restrictions, or other trade measures on top of existing duties.
- Public comment deadline is April 15, 2026 (docket USTR-2026-0067); public hearings scheduled May 5–8, 2026 at the U.S. International Trade Commission.
- U.S. importers, exporters, and manufacturers with supply chain exposure to any of the 16 targeted economies should assess risk and consider filing comments or requesting to testify.
'Structural Excess Capacity' Alleged
The Trump administration this week launched 16 new investigations under Section 301 of the Trade Act of 1974. These investigations target what the administration considers "structural excess capacity and production" in manufacturing sectors across a wide range of countries. If your business involves importing goods from — or manufacturing in — any of the countries listed below, this could directly affect you.
In plain terms, the U.S. government believes that certain foreign countries are producing far more manufactured goods than their own markets can absorb. That surplus production then gets exported— often to the United States — driving down prices and, in the Administration's view, hurting American manufacturers and workers. These investigations are the Administration's way of building a formal record to decide whether to impose new trade measures, including additional tariffs, to address the problem.
U.S. Trade Representative Jamieson Greer put it bluntly: "The United States will no longer sacrifice its industrial base to other countries that may be exporting their problems with excess capacity and production to us".
Which Countries Are Under Investigation?
The 16 economies targeted are: China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India.
That is an extraordinarily broad list. It includes nearly every major manufacturing economy and many key sourcing destinations for U.S. importers.
Which Industries Could Be Affected?
The investigation covers a long list of manufacturing sectors. If your business touches any of the following, you should pay close attention:
Aluminum, automobiles and auto parts, batteries, cement, chemicals, electronics, energy goods, glass, machine tools, machinery, non-ferrous metals, paper, plastics, processed food and beverages, robotics, satellites, semiconductors, ships, solar modules, steel, and transportation equipment.
What Could Happen Next?
It is important to understand that this is an investigation—not a final action. No new tariffs have been imposed yet. However, Section 301 is the same legal tool the Administration has used in the past to impose significant tariffs, most notably on goods from China.
If the Trade Representative ultimately finds that a country's practices are "unreasonable or discriminatory" and that they burden U.S. commerce, USTR has broad authority to take action. That action could include new tariffs, import restrictions, or other trade measures. Importantly, any measures imposed under Section 301 may be in addition to tariffs and duties already in place under other trade laws, such as Section 232.
Key Dates You Need to Know
- March 11, 2026 — Investigation initiated
- March 17, 2026 — Docket opens for written comments
- April 15, 2026 — Deadline for written comments and hearing requests
- May 5–8, 2026 — Public hearings begin at the U.S. International Trade Commission, Washington, DC
Post-hearing rebuttal comments will be due seven calendar days after the last hearing day.
How to Participate
The government is accepting public comments and hearing testimony from interested parties — including importers, exporters, manufacturers and trade associations. Here is what you need to know about participating:
Written comments can be submitted through the USTR online portal under docket number USTR-2026-0067. If you want to testify at the hearing, you must submit a separate request to appear under docket number USTR-2026-0068, along with a summary of your testimony. Testimony at the hearing is limited to five minutes, and all submissions must be in English.
If your submission contains confidential business information, pages containing such information must be clearly marked "BUSINESS CONFIDENTIAL," and you must also submit a public version.
For procedural questions, you can contact the USTR Section support line at (202) 395-5725.
What Should You Do Right Now?
If your supply chain, manufacturing operations, or export markets involve any of the 16 targeted economies, we recommend taking the following steps promptly:
First, assess your exposure. Review which of your products or sourcing relationships fall within the sectors and countries under investigation. Second, consider whether to file comments or testify. The April 15 deadline is approaching quickly, and participation is an important opportunity to make your voice heard before any trade measures are decided. Third, begin preparing data and documentation that supports your position—whether that means showing that your industry complements rather than competes with U.S. production, or that additional tariffs would harm your business and American consumers.
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