Insights · Forced labour
The UK has no forced labour import ban. UK goods now carry a 10% US tariff because of it.
Since 24 July most UK goods entering the US carry an extra 10% duty, because Washington judges UK forced labour rules too weak. A UK ban is years away. US buyers want the evidence now, and the EU’s own ban follows in December 2027.

In March the US trade office opened investigations into 60 economies, the UK among them, to test whether each one stops goods made with forced labour at its border. It found that the UK has only a partial regime. The result is an extra 10% duty on most UK goods entering the US, in force since 24 July 2026, with no end date.
The tariff is about the UK’s laws, not your suppliers. It still changes the conversation with your US customers.
If a US or EU customer has sent a forced labour questionnaire
Customer Questionnaire Response · Fixed fee · 5 working days. Send your customer a complete answer they will accept, with the evidence behind each reply. Up to 40 questions.
Why the UK was caught
The Modern Slavery Act asks large companies to report on their supply chains. It does not stop goods at the border. The US already has an import ban, and the EU’s applies from 14 December 2027. The UK has neither.
A UK ban is coming, slowly
In July the trade minister said he hoped for some form of import ban before the end of this Parliament in 2029, and accepted that the process is slow. Due diligence comes first.
The US notice leaves a door open. It allows exemptions for UK products where that would encourage the UK to adopt and enforce a ban.

Who feels it most
The pressure is highest for UK firms selling into the sectors US Customs watches most closely: clothing and cotton, aluminium, polysilicon, seafood, copper and steel.
Your evidence will not lift the tariff
The tariff applies to the country, not the company. But your US customer is held to its own standard. US Customs’ 2026 guidance tells importers to do their checks before goods arrive, not after a detention. A buyer who must prove its own supply chain will keep the suppliers who can prove theirs.
Your evidence decides whether your US customer can keep buying from you. The same evidence will answer EU buyers when their ban applies.
What to check this quarter
- Check the tariff code. See whether your products appear on the US list of UK exemptions. Goods already covered by Section 232 tariffs, such as steel and aluminium, are treated separately.
- Review what you have sent. List the US customers who have asked about forced labour in the past year, and what you sent back.
- Name the plant. For each key input, identify the plant that made it, not only the trading company that sold it.
- Test your statement. Make sure your Modern Slavery statement says only what you can evidence.
Where we come in
Meridian Intermediaries builds the evidence file behind your answer to a US or EU buyer:
- each key input traced to the plant that made it;
- owners screened against US, UK and EU lists;
- every link graded, so your customer can see what is proven.
The same file serves your US customers now and the EU ban in 2027.
Has a US customer sent a forced labour questionnaire? Request a Questionnaire Response → or speak to us first.
Sources
- USTR proposes 10% to 12.5% tariffs in Section 301 investigations of the regulation of imports produced with forced labor (White & Case, June 2026)
- Notice of Actions in Section 301 Investigations related to the importation of goods produced with forced labor (Federal Register, 28 July 2026)
- Section 301 Forced Labor Tariffs: What Just Changed for Global Shippers (C.H. Robinson, July 2026)
- Forced Labor Section 301 Tariffs Imposed to Replace Expiring Section 122 Tariffs (Baker Donelson, July 2026)
- Section 301 forced-labor tariffs (Zonos, 2026)
- UK eyes forced labour ban within three years (Just Style, 8 July 2026)
- New Compliance Tools: CBP Issues Comprehensive Forced Labor Guidance (Holland & Knight via Mondaq, July 2026)
- EU Forced Labour Regulation: key takeaways from the European Commission’s June 2026 guidelines (HLC, 2026)
Published 4 November 2026. General information, not legal advice; the position may have changed since publication.
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