IN Brief:
- The US is applying additional tariffs to goods from 60 economies covering 99.4% of American imports.
- UK goods generally face a 10% rate, while selected EU products may face total tariff rates of 10% or 12.5%.
- Food manufacturers will need greater visibility into labour controls, country of origin, tariff classifications, and supplier documentation.
The Office of the United States Trade Representative has imposed additional tariffs on goods from 60 economies following an investigation into forced labour import controls, extending the commercial consequences of labour due diligence across food ingredients, agricultural commodities, packaging materials, and manufacturing inputs.
The economies covered by the action account for 99.4% of US imports, giving the measures a reach well beyond sectors traditionally associated with forced labour enforcement. Food businesses trading with the US will now have to consider labour controls alongside origin, customs valuation, tariff classification, and product eligibility when calculating landed costs.
Goods from the UK will generally face an additional 10% tariff. The treatment of EU products is more complex because the new rate interacts with existing most favoured nation duties, leaving selected products with a combined tariff level of either 10% or 12.5%.
Individual consignments will be treated according to their country of origin, tariff code, existing duty, and any applicable exclusion. Although the final action contains exemptions intended to limit disruption where suitable US alternatives are unavailable, eligibility depends on detailed customs classifications rather than broad descriptions of a commodity or material.
Raw materials, products considered likely to create disproportionate supply disruption, and selected goods supporting American production may receive different treatment. Manufacturers importing finished ingredients, packaging components, or processing equipment will still need to establish whether every item falls within an exclusion rather than relying on the status of the wider product category.
The final measures follow public hearings and more than 2,100 submissions, including over 1,600 comments on the proposed action. Labour due diligence, previously concentrated within procurement, sustainability, and corporate governance functions, is consequently moving closer to the customs and finance systems that determine whether goods enter the market at the expected cost.
Traceability enters tariff management
Food manufacturers have already extended traceability beyond immediate suppliers in response to deforestation, human rights, environmental, and food safety requirements. Even so, many businesses can identify where an ingredient was blended or packed without holding dependable information about cultivation, harvesting, extraction, or earlier conversion stages.
Complex ingredients and multilayer packaging structures create particular difficulties because several raw materials may pass through different countries before reaching the supplier named on the invoice. A nutritional premix, seasoning system, laminate, closure, or machinery component can contain inputs whose origin is not visible within ordinary purchasing records.
Supplier declarations may therefore need to be supported by facility records, chain of custody information, third-party audits, and documentation covering subcontractors. Businesses that buy through brokers, use spot markets, or change commodity sources frequently will face a heavier administrative burden than manufacturers operating through stable, directly managed supply relationships.
Tariff volatility was already pushing companies to reconsider sourcing, inventory, and routing decisions, with an Infios study finding that trade uncertainty was changing execution across international supply chains. Forced labour measures add a compliance variable that cannot be managed through additional stock or price negotiation alone.
European suppliers may gain or lose competitiveness according to the rate attached to their products and the treatment of competing origins. Producers facing a higher tariff may redirect volume towards Europe or other markets, while American buyers may consolidate orders with suppliers able to demonstrate stronger labour controls and lower tariff exposure.
Those changes could influence availability and pricing even where a European manufacturer has no direct sales into the US. Displaced ingredients or materials may return to regional markets, while alternative sources sought by American buyers could tighten supply elsewhere.
Classification errors also become more expensive when additional duties are involved. Food ingredients can move between tariff headings according to composition, concentration, processing, or intended use, while machinery parts may be classified differently when imported separately rather than as part of a complete production system.
Customs, procurement, technical, and compliance teams will need to work from consistent product records, particularly where formulations or suppliers change regularly. A tariff code selected from an outdated specification can produce incorrect duties, delayed clearance, or retrospective liabilities long after the goods have entered production.
Mapping US-bound products against the final tariff annexes will expose where origin evidence is incomplete, where supplier contracts need strengthening, and where alternative sources carry different commercial risks. Labour governance is becoming a measurable condition of market access, with weaknesses increasingly likely to appear first as a customs cost rather than an audit finding.
