Daniel N. Anziska and Ryan Last, attorneys in Troutman Pepper Locke’s Tariff + Trade Task Force Practice Group, authored “Forced Labor, Meet Section 301: New Tariffs Target 60 of America’s Biggest Trading Partners,” which was cited in the September 14, 2026, Coatings World article, “Are the Section 301 Tariffs Actually About Forced Labor, or Are They Just a New Trade Weapon?.”

  • Does the Fine Print Undercut the Headline Rate?
  • Partly. Trade attorneys Ryan Last and Daniel N. Anziska of Troutman Pepper Locke note the final action carved out 471 additional exempted tariff subheadings covering raw materials facing domestic supply shortages, pharmaceuticals, and goods already subject to Section 232 tariffs on steel, aluminum, copper, and semiconductors. Their assessment: “these tariffs appear to exempt a substantial proportion of Asia’s current trade flows with the U.S., potentially moderating the practical impact on importers sourcing from the region relative to the headline rates.” A 10-12.5% headline rate reads differently once a substantial share of actual trade volume turns out to be carved out.
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