Forced Labor

The Fight Against Forced Labor: Enforcement, Policy, and Global SupplyChains in 2025

ByAnnik Sobing

Forced labor remains a critical human rights and trade issue, with governments and businesses worldwide intensifying efforts to keep goods produced under coercion out of global supply chains. In the United States, Customs and Border Protection (CBP) has taken a leading role in enforcing laws that target forced labor, particularly through new legislation and international cooperation. Here’s a look at how enforcement is evolving, what the latest data shows, and where the fight is headed.

What Is Forced Labor and How Does the U.S. Enforce Against It?

Under U.S. law (19 U.S.C. 1307), forced labor is defined as any work or service exacted from a person under menace of penalty and for which the worker does not offer themselves voluntarily. CBP enforces this law through several mechanisms:

  • Withhold Release Orders (WROs): These orders block the entry of goods suspected of being produced with forced labor.
  • Findings: Official determinations that certain goods are made with forced labor, leading to their exclusion from U.S. markets.
  • Uyghur Forced Labor Prevention Act (UFLPA): This law creates a rebuttable presumption that goods from China’s Xinjiang region or from entities on the UFLPA Entity List are made with forced labor, unless importers can prove otherwise.
  • Countering America’s Adversaries Through Sanctions Act (CAATSA): This act targets goods produced by North Korean nationals, barring their entry into the U.S.

CBP’s enforcement activity has ramped up in recent years:

  • FY 2025 (to March 31):
    • 2 new WROs issued
    • 1 new Finding published
    • Over 6,000 shipments stopped, valued at more than $97 million
    • 51 active WROs and 9 active Findings as of spring 2025
    • 11 WROs superseded by UFLPA enforcement, reflecting the growing reach of this law
  • Targeted Sectors: Electronics (especially solar products), apparel, footwear, textiles, and industrial materials are among the most frequently detained goods. High-priority sectors now also include aluminum, polyvinyl chloride (PVC), and seafood.
  • Global Impact: The U.S. is not alone—countries like Canada and the UK are also tightening forced labor enforcement, and international collaboration is increasing.

The Uyghur Forced Labor Prevention Act (UFLPA): A Game Changer

The UFLPA, first implemented in 2022 and updated in 2024, has significantly expanded the U.S. government’s ability to block goods linked to forced labor in China’s Xinjiang region. The law’s “rebuttable presumption” means that importers must provide clear evidence that goods from Xinjiang or listed entities are not made with forced labor. Since its implementation, CBP has reviewed over 8,500 shipments valued at more than $3.3 billion, and the UFLPA Entity List has grown to 68 companies.

Business and Policy Implications

  • Due Diligence: Companies face increasing pressure to trace their supply chains and prove their goods are free from forced labor. This includes more robust documentation, audits, and technology-driven transparency.
  • Penalties and Detentions: Shipments suspected of forced labor links can be detained, denied entry, or destroyed, with significant financial and reputational consequences for importers.
  • International Cooperation: The U.S. is working with partners in the EU, Canada, Japan, and Mexico to harmonize enforcement and share data, aiming for a unified front against forced labor.

Looking Ahead: Challenges and Opportunities

Despite progress, forced labor remains a massive global problem, with an estimated 50 million people affected and $236 billion in annual illegal profits. Climate change, migration, and complex supply chains continue to create vulnerabilities. The U.S. government and its partners are responding with more aggressive enforcement, expanded entity lists, and new strategies to identify and block tainted goods.

As enforcement grows more sophisticated, businesses must adapt quickly or risk losing access to major markets. For consumers and advocates, the trend is clear: forced labor is no longer tolerated in global trade.

Forced Labor

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Sources

  1. U.S. Customs and Border Protection: Forced Labor Enforcement
  2. CBP: Forced Labor | U.S. Customs and Border Protection
  3. ArentFox Schiff: Forced Labor Enforcement
  4. USTR: Forced Labor Enforcement Task Force Publishes Updated UFLPA Strategy
  5. CBP: April 2025 Monthly Update
  6. Global Training Center: The Fight Against Forced Labor—Recent Developments and Future Outlook

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