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USTR Holds Section 301 Hearing — Timing Raises Doubt Section 301 Can Fully Backstop July 24 Section 122 Cliff

| Recession Risk

USTR held its public hearing on the proposed Section 301 forced-labor tariffs. Under standard rulemaking procedure, a final rule must be published at least 30 days before taking effect — meaning that even an expedited Section 301 rule may not be ready to fully replace Section 122 authority when it lapses on July 24, absent Congressional action. This raised the prospect of a coverage gap in tariff collection at the cliff date, a risk not previously priced into most tariff-revenue projections.

USTR hearing raises doubt Section 301 tariffs will be ready to backstop the July 24 Section 122 cliff
USTR hearing raises doubt Section 301 tariffs will be ready to backstop the July 24 Section 122 cliff — Dorsey & Whitney