As Section 122 Nears Expiration, New Section 301 Tariffs Loom for the Optical Industry
Alexandria, VA (June 4, 2026) – Following the U.S. Supreme Court's February decision limiting presidential authority under IEEPA, Section 122 duties have been in effect, but are set to expire July 24, 2026. Now, the U.S. Trade Representative (USTR) has announced proposed new tariffs under Section 301 of the Trade Act of 1974, citing forced labor concerns across more than 60 countries. For the optical industry, which sources frames, lenses, and components from many of the named countries, the impact could mean additional costs at every level of the supply chain.
Unlike existing Section 301 duties, which date back to 2018 and address deceptive and unfair trade practices, these new proposed tariffs specifically target countries the USTR has determined either lack effective forced labor import prohibitions or are failing to enforce them.
New Proposed Tariffs Under Section 301
The USTR is proposing additional Section 301 forced labor tariffs at two tiers:
- A 10% additional tariff on imports from 14 countries and regions, including the European Union, United Kingdom, Canada, Mexico, Taiwan, and Malaysia.
- A 12.5% additional tariff on imports from 46 additional countries, including China, India, Japan, South Korea, Vietnam, and Thailand.
Separately, the USTR announced findings from its Section 301 investigation into Brazil's trade practices, proposing an additional 25% tariff on a broad range of Brazilian-origin goods. That tariff is expected to take effect after July 15, 2026.
Goods already subject to Section 232 duties will not face additional Section 301 tariffs under the current proposal. Certain product categories are also excluded from scope.
No implementation date has been established. The USTR has opened a public hearing and written comment period before any final determination is made.
Additional Investigations Pending
The USTR also has ongoing Section 301 investigations into structural overcapacity in manufacturing across a number of countries, including China, the EU, Japan, South Korea, Vietnam, and others. The Vision Council will provide updated guidance as those investigations are resolved.
Additionally, the Section 232 investigation into medical devices, which may affect optical products, remains pending, with an announcement expected soon.
“The tariff landscape continues to shift, and we know our members need clear, timely guidance to make informed decisions," said Omar Elkhatib, Director of Government Relations at The Vision Council. "As these new Section 301 proposals add another layer of uncertainty, we are closely monitoring these developments and will continue to provide the tools, resources, and expertise our members need to navigate what comes next."
Upcoming Webinar
The Vision Council is planning a member webinar featuring Rick Van Arnam, Regulatory Affairs Counsel, to review the proposed Section 301 changes, outline what members should do before the comment period closes, and address outstanding questions related to the IEEPA refund portal.
Registration details and timing will be shared via member communications soon.
Resources for the Industry
The Vision Council offers a suite of resources to help members respond to the ongoing impacts of trade and tariff policy.
- Latest Tariff Developments: Ongoing updates on policies and actions affecting the optical industry.
- Tariff Dashboard: A simulator available to members of The Vision Council that models the financial implications of tariffs on imports.
- Industry Resources & Guidance: Country-specific duty explanations, archived webinar recordings, and more.
The Vision Council will continue monitoring these developments and providing members with timely updates, practical guidance, and advocacy support.