The Fight Against Forced Labor: Recent Developments and Future Outlook

As we approach the middle of 2025, the global fight against forced labor continues to intensify. Recent data and policy updates reveal both progress and ongoing challenges in this critical human rights issue.

Current Enforcement Actions

U.S. Customs and Border Protection (CBP) has been actively enforcing measures against forced labor:

  • In FY 2025 (as of December 31, 2024):
    • 1 new Withhold Release Order (WRO) issued
    • 1 new Finding published
    • 2,672 shipments stopped due to forced labor concerns
    • $80.42 million value of shipments stopped

These figures demonstrate the U.S. government’s commitment to preventing goods produced with forced labor from entering the market.

Policy Developments

The United States Trade Representative (USTR) released its first-ever Trade Strategy to Combat Forced Labor in January 2025. This comprehensive approach outlines how the U.S. will use trade tools to address forced labor, marking a significant step in policy developments.

Additionally, the Department of Homeland Security announced the addition of 37 PRC-based companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List in January 2025, further tightening restrictions on goods potentially produced with forced labor.

Global Efforts and Challenges

While exact current figures are not available, the most recent estimates suggest that over 50 million people worldwide are affected by modern slavery, with forced labor generating $236 billion in illegal profits annually.

Climate change continues to exacerbate the issue, with climate-related displacement affecting millions and increasing vulnerability to exploitation.

Looking Ahead

As we move further into 2025, several key trends are emerging:

  1. Increased Enforcement: Countries like Canada and the UK are ramping up enforcement of forced labor laws. Canadian companies face a May 31, 2025 deadline for reporting on their forced labor mitigation efforts.
  2. Technology and Data Sharing: There’s a growing emphasis on leveraging technology and improving data sharing strategies to detect forced labor patterns and protect victims.
  3. Supply Chain Due Diligence: Companies are under increasing pressure to implement robust due diligence processes to identify and address forced labor risks in their supply chains.
  4. International Collaboration: The U.S. is actively engaging with partners like Canada, the EU, Japan, and Mexico to develop coordinated approaches to combat forced labor.
  5. Sector-Specific Focus: New high-priority sectors for enforcement have been identified, including aluminum, polyvinyl chloride (PVC), and seafood.

The fight against forced labor remains a complex and evolving challenge. As governments and organizations continue to refine their strategies and increase enforcement efforts, businesses must stay vigilant and proactive in addressing this critical issue throughout their supply chains.

Forced Labor

Forced Labor with emphasis on Supply Chain Tracing

Participants will also explore the role of technology and tools in supply chain tracing, including a review of global regulations and a detailed case study on WRO/UFLPA. Throughout the course, interactive activities, discussions, and reflection will empower participants to apply their learning to real-world scenarios and professional contexts, fostering a comprehensive understanding of forced labor supply chain tracing.

  1. U.S. Department of Homeland Security:Β https://www.dhs.gov/archive/news/2024/07/09/fact-sheet-just-two-years-forced-labor-enforcement-task-force-and-uyghur-forced
  2. International Trade Today:Β https://internationaltradetoday.com/article/2025/01/14/ustr-publishes-trade-strategy-to-combat-forced-labor-2501140090?BC=bc_67adcce7490aa
  3. Miller & Chevalier:Β https://www.millerchevalier.com/publication/trade-compliance-flash-uflpa-enforcement-2024-year-review
  4. Office of the United States Trade Representative:Β https://ustr.gov/about-us/policy-offices/press-office/press-releases/2025/january/ustr-releases-first-ever-trade-strategy-combat-forced-labor
  5. Venable LLP:Β https://www.venable.com/insights/publications/2025/01/2025-preview-navigating-new-customs-leadership

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