Background

The Department of Labor has added 32 products to, and removed one from, its list of foreign-made goods it has reason to believe are produced by child and/or forced labor in violation of international standards. This list also identifies for the first time downstream goods produced with inputs made with forced or child labor.

Goods Made With Forced/Child Labor

The DOL list, which is updated every two years, now totals 467 line items representing 158 products from 77 countries. This year the DOL has removed cotton from Uzbekistan from the list and added the following.

Bangladesh: garments (forced labor)

Brazil – acai berries (child labor)

Cameroon – gold (child labor)

Ecuador – bovines, hogs, poultry, rice (child labor)

Ghana – bovines, textiles, rice (forced labor)

India – tea, thread/yarn (forced labor)

Indonesia – palm oil products (child labor and forced labor)

Kenya – cattle (child labor)

Pakistan – baked goods, bovines, dairy products, electronics, furniture, garments, rice, textiles (child labor)

Zimbabwe – gold (child labor)

The DOL is required to take steps to ensure that the goods on this list are not imported into the U.S. if they are made with forced or child labor, including working with producers to help set standards to eliminate the use of such labor.

Downstream Products

Under a mandate from a 2018 law, this year’s DOL list includes for the first time goods that are produced with inputs made with forced or child labor. Such goods being added this year include the following.

China – photovoltaic ingots, photovoltaic wafers, solar cells, and solar modules (made with polysilicon made in China with forced labor) and lithium-ion batteries (made with cobalt ore mined in the Democratic Republic of Congo with child labor)

Indonesia – crude palm oil, crude palm kernel oil, refined palm oil, refined palm kernel oil, and oleochemicals (made with palm fruit harvested by forced/child labor in Indonesia

Additional downstream goods made from inputs on the DOL list that may face labor risks, but for which the DOL requires further evidence tying production to a particular country, include the following.

- silica-based products and solar products (made with polysilicon from China)

- cell phones, electric cars, laptops, medical implants, turbine blades, and vacuums (made with cobalt ore mined in the DRC)

- animal feed, baked goods, beverages, biofuels, cooking oils, household and industrial products, infant formula, and personal care and cosmetic products (made with palm fruit from Indonesia)

Other Measures

The DOL has also:

- updated its mobile apps that contain the latest data on goods produced by child or forced labor and provide detailed guidance on how to develop and implement robust social compliance systems that prevent, detect, and address child labor in global supply chains;

- launched the ILAB Knowledge Portal for researchers, civil society organizations, other governments, and international organizations seeking to implement best practices in combating child labor and forced labor; and

- updated its Better Trade Tool, which overlays the list of goods produced by child labor or forced labor with international trade data to highlight U.S. imports at higher risk of being produced using child or forced labor. 

Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address 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.

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