The UK forced labour tariffs now being levied by Washington have exposed an uncomfortable gap: Britain, which spent months celebrating its early trade deal with the United States, finds itself in a structurally weaker position than the European Union it left behind.
The mechanism is blunt. On 2 June 2026, the Office of the United States Trade Representative (USTR) formally determined that policies across 60 economies (covering their failure to prohibit imports of goods produced with forced labour) constitute unreasonable practices that burden US commerce, making them actionable under Section 301 of the Trade Act of 1974. The resulting tariffs, set at either 10% or 12.5%, landed on allies and rivals alike.
The investigation itself had begun on 12 March 2026, according to Mayer Brown, a day after a parallel probe into manufacturing overcapacity was launched. These are, in the words of one industry figure cited in the original reporting, ‘tariffs in search of an authority.’ The forced labour rationale does what the previous justifications could not: it shores up the levies against challenge in Congress or the courts.
Why UK Forced Labour Tariffs Now Trail the EU’s Rate
The raw headline numbers look similar: both the UK and the EU sit at a 10% rate. The difference lies in the composition. The EU’s is a flat rate. The UK’s applies alongside other tariffs across a range of goods including footwear and textiles. The British Chambers of Commerce trade expert William Bain has pointed to the resulting competitive advantage for EU exporters into the US across several sectors.
When you run the trade-weighted effective tariff rates, the EU comes out at 8.5% against the UK’s 6.8%. The UK’s number is lower in isolation, but the EU’s rate encompasses a far larger volume of trade, and the EU has secured better treatment precisely because it passed a formal ban on goods produced with forced labour, which the UK has not.
The EU’s legislation, Regulation (EU) 2024/3015, was adopted by the European Parliament and Council on 27 November 2024, entering into force on 13 December 2024. As Squire Patton Boggs set out, it prohibits economic operators from placing, selling, or exporting any products made with forced labour anywhere in the EU market. Washington read that legislation as meaningful alignment. The UK has nothing equivalent.
Britain’s Voluntary Approach Is Now a Trade Liability
The UK’s framework rests on Section 54 of the Modern Slavery Act 2015, which requires large companies to publish annual statements on steps taken to prevent modern slavery in their supply chains. It is a transparency and disclosure regime, not an import ban. The distinction is now costing Britain in tariff terms.
Of the 60 economies targeted under the USTR probe, 54 have neither imposed nor effectively enforced a forced labour import prohibition. The UK is among them. That is the lever Washington is pulling.
In December 2024, the UK government responded to the House of Lords Modern Slavery Act Committee by acknowledging that introducing import laws banning goods produced with forced labour would require legislative change, and said it was ‘reviewing how best it can use legislative and non-legislative measures to tackle forced labour and increase transparency in global supply chains.’ No timetable was given.
The government has since welcomed Chinese car imports and is exploring a services trade deal with Beijing. Both moves complicate the picture. Any formal ban on forced labour goods would function, in practice, as a mechanism targeting China, particularly conditions in Xinjiang. The relationship with China has been a studied balancing act, and passing EU-style legislation would force a choice the government has so far avoided.
The broader context cuts both ways. China’s total trade with the US is broadly flat in the first half of this year versus the same period last year. Across the rest of the world it is up 21%, including 14% with the EU and 11% with the UK. Trade is being rerouted regardless of what London decides. The question is whether Britain wants to make that rerouting cheaper for its exporters into the US, or whether it prefers to maintain its existing side deals on medicines, steel, aluminium, and cars without disturbing the China relationship.
There is scope for a better deal, as the USTR framework explicitly rewards economies that pass a formal ban. Whether the government will pursue that path before the next round of tariff reviews is the decision that will define whether the early UK-US deal was a foundation or a ceiling.
