A complaint filed with U.S. Customs and Border Protection April 6 seeks to ban imports of all cotton lint, yarn, fabric and other cotton goods produced in Turkmenistan because they are allegedly made with forced labor. In light of the March 10 elimination of the “consumptive demand” clause in U.S. trade law, which allowed goods believed to be made under forced labor conditions to be imported under certain circumstances, the complaint calls on CBP to classify all cotton goods from Turkmenistan as illicit, issue an exclusion order and an immediate detention order against all pending and future imports of such goods, and require port directors to withhold release of such goods into the U.S.

The complaint asserts that manufacturers in Turkmenistan use only cotton produced with forced labor to manufacture cotton yarn, fabrics, linens, apparel and other cotton products. Specifically, all cotton is allegedly produced for a government monopoly through a state-order system for cotton production in which citizens are forcibly mobilized to grow and harvest cotton by the government under threat of penalty. The complaint notes that the U.S. Department of Labor has listed cotton from Turkmenistan on its list of goods produced by child or forced labor since 2009 and that the International Labor Organization has registered “deep concern” about the widespread use of forced labor in cotton production in Turkmenistan.

According to a joint press release, Turkmen cotton enters global markets via cotton traders that openly buy and sell it around the globe as well as retailers that source ready-made cotton goods from Turkmenistan. Since Turkmenistan imports no cotton, the press release states, all cotton goods produced there are made from domestically sourced cotton, all of which is produced in the government’s forced labor system. Import records indicate that cotton goods are being imported from Turkmenistan into the United States.

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