Section 301 Investigations Signal New Phase in U.S. Trade Policy

Mar 12, 2026
Summary

  • The Trump administration has launched Section 301 trade investigations into 16 major trading partners, including China, the EU, Japan, India, and Mexico, with electronics identified as a sector of concern.

  • The investigations follow the Supreme Court ruling against IEEPA-based tariffs and use Section 301, which requires a formal process with public comments and hearings before any trade remedies.

  • No new tariffs yet, but potential future trade actions could affect the electronics supply chain; the Global Electronics Association will submit comments and encourage members to participate.

The Trump administration yesterday announced the launch of Section 301 trade investigations into 16 key trading partners, including China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, South Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India.

The investigations, conducted by the Office of the United States Trade Representative (USTR), are aimed at addressing what the administration characterizes as unfair trade practices relating to structural excess capacity and production in manufacturing sectors. Electronics were specifically identified as an area of concern.

Jamieson Greer, the USTR, has also signaled that additional investigations will be launched related to digital services taxes and discrimination against U.S. technology companies, among other practices.

The backdrop: A new legal path after the IEEPA ruling

This action follows the Supreme Court of the United States’ February 20 ruling striking down the administration’s tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The move represents a significant shift in the legal framework the administration is using to pursue its trade agenda.

Unlike tariffs imposed under IEEPA, investigations conducted under Section 301 of the Trade Act of 1974 require a formal investigative process. This includes public comment periods and hearings before tariffs or other remedies can be implemented. The administration has indicated it intends to move on an accelerated timeline.

Why it matters: Potential impacts across the electronics supply chain

While no new tariffs are being imposed today, the investigations lay the groundwork for potential future trade actions that could directly affect companies across the electronics value chain — from semiconductor sourcing to finished systems.

What members should do: Prepare comments and engagement

The Global Electronics Association will file comments with the USTR by the April 15 deadline and has submitted a request to testify at the May 5 hearings. The association encourages member companies to prepare their own comments as well.

What’s next: Monitoring developments

We will continue to monitor these investigations and provide updates as developments occur. In the meantime, members with questions are encouraged to reach out to the Global Electronics Association advocacy team.