India stressed that trade issues with the United States should be resolved through bilateral trade negotiations rather than unilateral measures, and urged the US Trade Representative to reconsider the proposed 12.5% tariff, citing inconsistencies in its Section 301 investigations into forced labor concerns.
While participating in the public hearing, Joint Secretary, Ministry of Commerce Brij Mohan Mishra emphasized that in light of India’s genuine involvement in forced labor issues, it strongly expresses its concerns over the USTR’s decision.
India takes the elimination of forced labor seriously as a constitutional obligation and as a matter of international law and principle.
“India would like to highlight its concerns regarding the US Trade Representative’s report and its findings against India,” he said.
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The USTR did not meet the relevant legal standards under Section 301(d) of the Trade Act. He added that the mere absence of a prohibition on the importation of forced labor without an evidentiary basis for other legal requirements could not be construed as unreasonable under Article 301.
The USTR’s decision does not provide a rationale for nationwide tariffs and impermissibly lumps 46 economies (including India) into a single category, according to a transcript of the July 8 hearing posted on the USTR’s website.
The USTR Section 301 investigation report concerns the failure to effectively enforce and implement a ban on the import of goods produced by forced labor.
India stated that the methodology adopted was particularly flawed because the identification was based on case studies of a small number of economies and relied on broad trade patterns.
He said the report relies on broad data and presupposes that imports of the economy flagged for these items involving imports made with forced labor are exported to the United States without providing any sector- or country-specific evidence of actual links to forced labor.
As far as India is concerned, he said, there is insufficient and insufficient evidence that the absence of a ban on the import of forced labor leads to an unfair competitive advantage at the expense of American industry.
“In conclusion, it is suggested that the US Trade Representative reconsider the imposition of tariffs in light of the discrepancies identified in the report in the Federal Register Notice. We request that any trade issues be addressed within the framework of bilateral trade negotiations between India and the United States, and not through unilateral measures such as this investigation,” he added.
India remains ready to engage constructively with the US Trade Representative through consultation and dialogue on any specific concern.
Submitting submissions on behalf of the Agricultural and Processed Foods Export Development Authority (APEDA), Shreyans Gupta, Principal Secretary at the Embassy of India in Washington, D.C., said the Export Promotion Authority (APEDA) objects to the US Trade Representative’s observations on the import of rice allegedly manufactured with forced labor into India and the alleged impact on these imports of distorting the competitive conditions for export and domestic sale of rice produced in the United States.
It is important to note that India’s rice imports are very small and meet the targeted demand for specific and specialized varieties of rice.
Gupta said that the total value of rice imported into India compared to the value of rice exported from India to the US is not even three per cent.
He added that there are regulatory controls in place that prevent the export of rice imported from India that was produced using forced labor.
Export of rice from India to the United States is permitted only through rice mills and processing units registered with the Ministry of Agriculture.
“For these reasons, the current investigation against India may be canceled without prejudice,” Gupta said, demanding that Indian rice be exempted from the proposed duties if the proceedings continue.
The Ficci Chamber of Industry stated that the proposed additional tariff deserves careful reconsideration.
“The additional tariffs will increase costs not only for Indian exporters, but also for US manufacturers, importers, retailers, and ultimately US consumers,” the chamber said, adding that higher tariffs would increase costs for companies that already follow compliance standards.
It urges reconsideration of the proposed additional tariffs in light of India’s legal and regulatory safeguards, the extensive compliance mechanisms adopted by Indian industry, and the potential impacts on legitimate trade and resilient U.S.-Indian supply chains.
CII has also maintained that the proposed additional tariff of 12.5 per cent is not supported by the evidence presented, and is unlikely to advance the stated policy objective.
The US Trade Representative’s report does not prove that India’s policy framework burdens US trade, the chamber said.
The US Trade Representative launched two separate Section 301 investigations on March 11 and 12, 2026, covering 60 economies over concerns related to forced labor and industrial overcapacity.
On June 3, the US Trade Representative released its findings in its forced labor investigation and proposed additional tariffs on imports from these economies.
The proposal includes a 10 percent tariff on imports from Canada, Ecuador, the European Union, Indonesia, Mexico and Pakistan, and a 12.5 percent tariff on imports from 54 other economies, including India and China.
This measure is still only a proposal and has not yet been finalized.
The US Trade Representative will consider these comments and testimony before making a final decision on the proposed tariffs.
