USTR Tariff Probes Target Vietnam, India, and 14 More

On March 11, 2026, the U.S. Trade Representative launched what may be the most consequential restructuring of U.S. tariff policy since the original China Section 301 tariffs in 2018. USTR Ambassador Jamieson Greer initiated Section 301 investigations into 16 countries — including Vietnam, India, Cambodia, Thailand, Indonesia, and Mexico — for alleged "structural excess capacity" in manufacturing.1

If you spent the past three years diversifying your supply chain away from China, this is not the news you wanted to hear.

Why Section 301 Is Different From What Came Before

You may be thinking: didn't the Supreme Court just strike down IEEPA tariffs? Yes. But Section 301 is a different legal authority entirely, and it is significantly more durable.

Section 301 of the Trade Act of 1974 gives the USTR broad authority to impose tariffs when a foreign country's policies are found to be "unreasonable or discriminatory" and burden U.S. commerce. You know Section 301 from the China tariffs that have been on the books since 2018 — the same 7.5%–100% duties that survived the Supreme Court challenge, multiple administrations, and countless trade negotiations. They're still there today.

Unlike Section 122 — the 15% temporary surcharge imposed after the Supreme Court struck down IEEPA tariffs last month — Section 301 carries no statutory time limit and no cap on tariff rates.2 Once finalized, Section 301 tariffs don't expire. The administration is explicitly using these new investigations to build a legally durable, long-term tariff architecture to replace the IEEPA authority it lost.

Who Is Under Investigation

The March 11 initiation named 16 economies: China, the EU, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, South Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India.1

Simultaneously, a second investigation targeting 60+ countries was launched for failing to enforce bans on forced labor in their supply chains — and Vietnam and India appear on both lists.

The sectors most exposed by country:

• Vietnam: Electronics, footwear, and apparel — the three largest categories that shifted from China after 2018. Vietnam ran a $178 billion bilateral goods trade surplus with the U.S. in 2025, up 40% from 2022.1

• Cambodia and Bangladesh: Garments and textiles. USTR alleges both governments deliberately built manufacturing capacity to absorb Chinese production displaced by earlier U.S. tariffs.

• Thailand: Automotive components and electronics. Manufacturing capacity utilization cited at below 60%.3

• India: Electronics, pharmaceuticals, chemicals, and engineered goods. India appears on both the overcapacity and forced labor investigation lists.

• Mexico: Manufacturing broadly, including nearshoring categories that grew under USMCA. USMCA-certified goods are currently exempt from the Section 122 surcharge — but that exemption is not guaranteed under a future Section 301 determination.

The Timeline You Need to Track

This process has a hard deadline. The Section 122 temporary surcharge expires on July 24, 2026.4 The administration is racing to have Section 301 tariffs legally in place before that window closes. Here's the schedule:

• April 15, 2026: Deadline for written comments and hearing appearance requests with USTR.

• April 28 – May 8, 2026: Public hearings in Washington D.C. — forced labor investigation first, then overcapacity. Industry associations are already mobilizing. These hearings are where product-specific carve-outs get argued and won.

• Mid-May 2026: Deadline for post-hearing rebuttal comments.

• Late July 2026: Target date for USTR affirmative determinations and tariff implementation, timed to coincide with the Section 122 expiration.

The key number: tariffs on Vietnamese or Indian goods could be announced and take effect within four months.

The China Plus One Problem

For years, "China Plus One" was the standard advice: keep some sourcing in China, but diversify to Vietnam, India, or Bangladesh to hedge tariff risk. That strategy was reasonable in 2021. It's more complicated now.

The administration's argument is straightforward: shifting production from China to Vietnam didn't shrink U.S. trade deficits — it moved them. Vietnam's bilateral surplus with the U.S. grew 40% between 2022 and 2025. From a policy standpoint, that doesn't look like supply chain diversification — it looks like tariff arbitrage.

For importers who genuinely moved production to Vietnam — real manufacturing with local materials and labor — the investigation does not automatically mean tariffs are coming. USTR must make affirmative legal determinations, and targeted countries are pushing back hard. Vietnam's government has already issued an official response arguing it "fully operates as a market economy."5 India and the EU will mount serious legal and diplomatic challenges.

But for importers routing Chinese-origin goods through Vietnamese or Cambodian facilities — or using Southeast Asian operations primarily as transshipment points — the risk is acute. CBP enforcement around origin claims has been tightening all year, and Section 301 tariffs apply to country of origin, not country of export. Getting that wrong in a post-investigation environment carries serious financial exposure.

What Importers Should Do Right Now

You don't need to make irreversible decisions today. But you do need to be preparing:

• Audit your country-of-origin documentation. If you source from Vietnam, India, or Cambodia, verify that your certificates of origin accurately reflect where substantial transformation occurred. This is not a compliance checkbox — it's financial risk management. A CBP finding that your "Vietnamese" goods are actually Chinese-origin is far more damaging than any new tariff rate.

• Run landed cost scenarios now. Model your shipments assuming new tariff rates of 10%, 20%, and 30% on goods from your Southeast Asian or Indian suppliers. Know the margin impact before July, not after. Your customs broker can help you build these models against your actual HTS codes.

• Watch the April hearings closely. The April 28 public hearings are where specific product categories get carved out or confirmed for tariff action. Which industries show up, which arguments gain traction, and which sectors face the most aggressive USTR posture will tell you where rates are actually going to land.

• Don't make irreversible sourcing changes yet. Section 301 investigations don't always result in sweeping tariffs. The 2017–2018 China investigation took over a year and resulted in phased, product-specific duties — not blanket rates. Diplomatic complexity with India, the EU, and Mexico could significantly temper the final outcome. Monitor the process before committing to major supply chain restructuring.6

• Look more seriously at Mexico and nearshoring. USMCA-certified goods have consistently received preferential treatment, and Mexico's political integration within the North American trade architecture makes sweeping Section 301 tariffs harder to implement there than in Southeast Asia. For applicable product categories, nearshoring to Mexico offers more structural tariff protection right now.

The Pattern Is Clear

Since 2018, U.S. trade policy has moved in one direction: broader tariff coverage, more durable legal tools, and less predictability for importers. The March 11 investigations are not an anomaly — they're the next phase of a deliberate restructuring of how the U.S. approaches global trade.

The importers who navigate this best won't be the ones who find the next tariff-free country. They'll be the ones with clean origin documentation, diversified sourcing across multiple geographies, and a real-time grip on landed costs when the policy environment shifts. And it will shift again.

If you want help modeling how potential new tariffs would affect your ocean freight costs or total landed cost from Vietnam, India, or other Southeast Asian suppliers, talk to the team at Cubic. We help importers build freight strategies that hold up regardless of what comes out of Washington.