국경 간 무역의 오늘 짚어야 할 10가지 — 2026년 6월 3일

1. USTR forced-labor §301 publishes a concrete action proposal — 60 economies, up to 12.5%. The June 1-2 Federal Register notice moves the forced-labor §301 track (hearings closed late April through early May) into a substantive proposal. Sixty economies are subject — including China, India, Japan, South Korea, Vietnam, Mexico, Brazil, the EU, Indonesia, Pakistan, Ecuador, Canada. Proposed ad valorem rate up to 12.5%. Comment deadline July 6; public hearings July 7.

2. The 60-economy list splits into two enforcement tiers. Fifty-four economies "failed to impose and effectively enforce a forced-labor import prohibition" — China, India, Japan, Korea, Vietnam, Mexico, Brazil, others. Six economies "have a prohibition but failed to effectively enforce it" — Canada, Ecuador, EU, Indonesia, Mexico, Pakistan. Rate intensity likely differs between tiers — the comment period will clarify.

3. The timeline interlocks with the §301 16-economy action. Forced-labor hearings July 7 + §301 16-economy action target July 24 + §232 pharma kickoff July 31 — three events within 25 days. This is USTR shipping anti-China levers in pipelined weekly cadence. CFO models need to treat early through late July as four discrete weeks with separate scenario builds, not a single monthly curve.

4. USTR simultaneously initiates a Brazil-specific §301 investigation. Brazil was separately docketed on June 1 — not on the forced-labor 60-economy list. Doesn't overlap with the forced-labor case. Covers core Brazilian exports to the US — coffee, iron ore, meat, pulp, sugar, ethanol. /route lookup shows the current aggregate rates by HS.

5. §122 judicial timeline — CAFC merits opinion most likely late 2026. The 5/29 deep-dive assumption that CAFC would rule before §301 takes over July 24 needs correction. FreightFigures and standard appellate-timeline analyses suggest CAFC merits opinions typically come 3 to 9 months after oral argument. On that cadence the §122 appeal's substantive ruling is unlikely to land before late 2026. Practically: §122 still gets collected under the CAFC administrative stay through July 24, with no judicial resolution by the time §301 takes the baton.

6. CAPE real bottleneck — Treasury hasn't issued paper checks since Feb 6. The operational detail that determines whether you actually get refunded: CBP stopped issuing any paper refund checks on February 6, 2026. Every IEEPA refund moves through ACH, period. IOR without registered ACE banking info = no refund, no matter how clean the CAPE Declaration. Approximately 1,880 entries are stuck on this. Action: log into ACE Portal this week and check the Importer sub-account's ACH details.

7. China State Council Order No. 834 confirmed — the supply-chain security regulation we flagged May 1. Our May 1 audit tagged the "PRC April 7 supply-chain security regulation" as a single-source signal pending verification. Today the proper source surfaces — State Council Order No. 834, promulgated March 31, the Provisions on the Security of Industrial and Supply Chains — China's first dedicated industrial/supply-chain security framework. Provides the legal foundation for MOFCOM + MIIT enforcement against foreign companies.

8. Rare earths — samarium, gadolinium, lutetium compounds added January 1, 2026. Not the April action — the actual move was in the January 1, 2026 update to China's 2026 Import-Export Licensing Catalogue. Mechanism is licensing, not embargo — you can still source these compounds, but only through suppliers holding valid MOFCOM export licenses. Multiple authoritative sources (CSET, Taylor Wessing) converge. This corrects our May 21 "single-source pending" framing.

9. §232 pharma 58 days from kickoff. 17 Annex III companies at 100% full value July 31. Other pharma companies September 29. Switzerland holds the 15% preferential tier. Ireland, India, China, Singapore, Belgium, Denmark, Germany, France, Italy stay default 100%. Load the §232 pharma preset in the Tariff Stack Calculator for aggregate-equivalent modeling by sub-category.

10. The July sequence locks in — Busan-truce 160 days. USMCA Round 2 June 16-17 (13 days) + forced-labor §301 comments due July 6 + hearings July 7 + §301 16-economy action July 24 + §232 pharma July 31 + USMCA Round 3 week of July 20 + Busan-truce expiry November 10 (160 days) — these eight lines form a tightly interlocking H2 policy calendar. The only two settled certainties: tariffs won't return to zero (Greer May 21) + export controls won't be lifted (MOFCOM May 20). The /updates feed syncs every official posting in real time and as of this month includes a snapshot version system — browse the policy archive by month.