Apparel, Shrimp Considered for Removal from Forced Labor List

Garments from Vietnam and shrimp from Thailand could be removed from a federal forced labor list under a proposal from the Department of Labor. The DOL is also seeking input on whether other products should be added to or removed from this list.

Executive Order 13126 prohibits federal agencies from acquiring goods produced by forced or indentured child labor, and the DOL maintains a list of products that it has a reasonable basis to believe might have been mined, produced, or manufactured with such labor. Federal contractors who supply the products on this list must certify that they have made a good faith effort to determine whether forced or indentured child labor was used to mine, produce, or manufacture them and that, on the basis of those efforts, they are unaware of any such use.

The EO 13126 list, which comprised 34 products from 26 countries as of its most recent update in July 2022, is available here.

The DOL is now proposing to remove garments from Vietnam (added to the list in 2012) and shrimp from Thailand (added to the list in 2009) from this list because it has preliminarily determined that the use of forced or indentured child labor in the production of these products has been significantly reduced.

Comments on this proposal – and on whether any other products should be added to or removed from the EO 13126 list – are due by June 10

Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address child and forced labor concerns around the world, including supply chain reviews, due diligence strategies, and proactive remediation. ST&R also maintains a frequently updated web page offering a broad range of information on forced labor-related efforts in the U.S. and around the world. For more information, please contact ST&R at supplychainvisibility@strtrade.com.