USTR extends Section 301 investigation of Vietnam's IP practices by three months
USTR extended its Section 301 investigation into Vietnam's intellectual property protection and enforcement practices by three months. Determinations are now due by February 28, 2027. No duties are set by this notice.
What this affects
VietnamThe update
The Office of the United States Trade Representative has determined to extend for three months the ongoing Section 301 investigation of certain acts, policies, and practices of the Government of Vietnam related to intellectual property (IP) protection and enforcement. The notice is effective as of November 3, 2026, at 12:01 a.m. EDT.
The investigation was initiated on May 29, 2026, under Section 302(b)(2) of the Trade Act of 1974, as amended, and does not involve a trade agreement. Section 304(a)(3)(A) normally requires findings on actionability and any action within six months of initiation. Section 304(a)(3)(B) allows nine months if the Trade Representative determines that the investigation involves complex or complicated issues requiring additional time, or if the foreign country is making substantial progress on IP legislation or enforcement.
USTR relied on the complexity ground, determining that the investigation involves complex or complicated issues that require additional time. The determinations on actionability and what action, if any, to take will be made by no later than February 28, 2027. The notice does not state any duty rate, product list, or tariff action.
Impact
The notice imposes no new cost today, but it keeps the possibility of Section 301 action against Vietnam open for longer. Importers sourcing from Vietnam should treat the investigation as a pending risk to landed cost when planning contracts and pricing into early 2027.
What to watch
The notice says only that determinations will come by February 28, 2027, and does not say what action, if any, USTR may take or which products could be affected. The deadline is an outer limit, so determinations could come earlier.
How to prepare
- 1Pull entry data for goods of Vietnamese origin
Knowing your volume and spend by product shows how much exposure you carry if action follows.
- 2Review supplier contracts for tariff allocation clauses
Check who bears new duties if a Section 301 action is announced during the term.
- 3Model landed cost under a possible additional duty
Scenario ranges help you assess margin and pricing risk without assuming any specific rate.
- 4Confirm origin documentation for Vietnam-sourced goods
Reliable country-of-origin evidence matters if any measure is later tied to origin.
- 5Monitor USTR and Federal Register notices
Watch the docket for hearings, comment windows, or determinations ahead of February 28, 2027.
Sources
- Notice of Determination To Extend Section 301 Investigation of Vietnam's Acts, Policies, and Practices Related to Intellectual Property Protection and Enforcement · Federal Register · November 10, 2026
- Section 301 Investigations Up as Congress Eyes Trade Authority · Legis1 · November 3, 2026
- Section 301 Probe of Vietnam Extended · Sandler, Travis & Rosenberg, P.A. · November 9, 2026
- Section 301 Tariffs on Medical Products: What USTR Set for Syringes, Gloves and Masks · CASRAI · October 31, 2026
We summarize published reporting and official notices. Always confirm rates and dates against the Federal Register or your customs broker before acting on them.