Canada has told the Office of the U.S. Trade Representative there is "no basis for the imposition of additional Section 301 duties on Canadian goods," in a written submission filed ahead of a three-day Washington hearing on the proposed tariffs Globe and Mail.

The submission responds to a process USTR chief Jamieson Greer opened in March 2025, when he announced Section 301 investigations into 60 countries, Canada among them, over enforcement of bans on forced-labour goods in supply chains Globe and Mail. Section 301 of the Trade Act of 1974 lets the USTR investigate and retaliate against foreign practices it deems unfair to U.S. commerce; it has been the legal vehicle for most of the Trump administration's country-specific tariff actions since the Supreme Court complicated the use of emergency economic powers earlier this year Reuters.

Greer's office has since proposed a two-tier tariff structure. Canada, Mexico, the United Kingdom and several other countries would face a 10 per cent duty for allegedly insufficient enforcement against forced labour; dozens of additional countries with partial or no bans would face 12.5 per cent Globe and Mail. Reuters reported the 12.5 per cent figure for the broader 60-economy group on June 3, 2026, after USTR determined those economies had failed to curb forced-labour-linked trade Reuters. Switzerland has separately rejected the investigation's findings outright Reuters.

Ottawa's case rests on distinguishing Canada's existing legal architecture from the enforcement gaps USTR alleges elsewhere. Canada has required annual supply-chain reporting to the federal government for several years, and a 2020 tariff amendment already made it illegal to import goods produced through forced labour, as Global Affairs Canada told a parliamentary committee in October 2024 GAC briefing. The department's contracting code was updated in May 2023 to add explicit language on human trafficking, forced labour and child labour GAC.

The submission's strongest card is Bill C-35, tabled last month. The legislation would create a public list of products tied to forced labour in specific regions, shift the burden onto importers to prove goods from listed regions were not produced through slavery, and require enhanced supply-chain tracing information for high-risk imports at the border Globe and Mail; Global Affairs Canada. Global Affairs published its news release on the bill on June 12, 2026, and the file sits alongside broader supply-chain-resilience commitments in the department's 2025-26 departmental plan GAC. Public Safety Canada, which administers reporting obligations under the existing supply-chain law, has noted that many internationally operating entities already fall under those requirements Public Safety Canada.

Industry has weighed in alongside government. The Canadian Chamber of Commerce, through vice-president Matthew Holmes, asked USTR to assess Canada separately from the broader 60-country cohort, to suspend the proposed 10 per cent duty while C-35's reforms take effect, and to prioritize bilateral enforcement cooperation over a blanket country-level tariff Globe and Mail. More than 1,500 written submissions from governments and industry groups were filed ahead of the hearing, a volume that signals how many trading partners view the investigation's methodology, not just its conclusions about their own compliance, as the point of contention Globe and Mail.

The dispute lands while Prime Minister Mark Carney is at a NATO summit, meaning the file is for now being managed by officials and industry rather than through direct leader-to-leader engagement CityNews Halifax. That timing matters procedurally more than symbolically: Section 301 processes move on their own administrative clock, built around comment periods and hearings rather than summit diplomacy, and Ottawa's rebuttal was always going to be filed by trade officials rather than argued in a leaders' meeting.

What distinguishes Canada's position from many of the other 60 countries under review is the argument that its forced-labour regime already predates the U.S. investigation by years, with C-35 layered on top rather than introduced in response to American pressure. Whether USTR treats that distinction as sufficient grounds for a carve-out, or folds Canada into the general 10 per cent tier regardless, will depend on findings from the Washington hearing and any subsequent determination, neither of which had been released as of this writing. Reuters reported as early as April 28 that the investigation, launched in mid-March, could produce new tariff actions against U.S. allies including Australia and Canada, a framing that has held through the process to date Reuters.