To aid in the development of its first-ever focused trade strategy to combat forced labor, the Office of the U.S. Trade Representative is inviting public comments through Aug. 5.

USTR states that this strategy will identify priorities and establish an action plan for utilizing existing and potential new trade tools to combat forced labor in traded goods and services. In developing this strategy USTR is conducting an interagency review of existing trade policies and tools used to combat forced labor, including forced child labor, to determine areas that may need strengthening and gaps that may need to be filled. USTR will use this analysis to establish objectives, priorities, new tools, and key action items to advance development of the strategy.

As part of this process USTR is inviting interested parties to submit comments, including on the following topics.

- actions the U.S. could pursue with like-minded trade partners and allies to combat forced labor as an unfair trade practice

- how the U.S. can bolster the forced labor components of trade agreements and trade preference programs to have greater effect

- new and innovative trade tools the U.S. can develop and utilize to advance efforts to combat forced labor in traded goods and services

- how the U.S. can make the development of trade policy on forced labor a more inclusive process

- additional recommendations for monitoring, tracing, or eliminating forced labor in traded goods and services in supply chains

The USTR strategy will support the Biden administration’s National Action Plan to Combat Human Trafficking, which also directs other federal agencies to take actions to better enforce the existing ban on imports of goods made with forced labor. This includes providing key private-sector partners with information about forced labor in product supply chains and increasing transparency regarding enforcement of withhold release orders.

Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address forced labor concerns, 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

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