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US Leads the Global Crackdown on Forced Labor

Written by Angela M. Santos, Lucas Rock, Jodi Tai (ArentFox Schiff) | Nov 30, 2022 9:26:56 PM

The US and EU have ramped up their enforcement initiatives to eliminate forced labor in supply chains. Importers, particularly in the fashion, electronics, solar, and automotive industries, should review the updated DOL List of Goods Made with Child Labor or Forced Labor for potential future CBP enforcement targets. 

What to Know

In August 2022, US Customs and Border Protection (CBP) targeted $266.5 million in goods for suspected use of forced labor, according to the agency’s operational statistics report. 

  • This includes goods targeted under the Uyghur Forced Labor Prevention Act (UFLPA) and Withhold Release Orders (WROs). 
  • On September 28, 2022, the US Department of Labor (DOL) updated its List of Goods Made with Child Labor or Forced Labor (Forced Labor List) with 32 additional products, including textiles, lithium ion batteries, palm oil products, and solar components. These products could potentially be targets for CBP enforcement in the future, particularly as CBP staffs up its Forced Labor Division. 
  • On September 14, 2022, the European Union (EU) issued proposed supply chain and forced labor regulations, which will affect many multinational corporations.
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