Forced Labor & Supply Chain Visibility Resources 

Enforcement of the prohibition of importation of goods mined, produced or manufactured by forced labor is on the rise. This page gathers together information and resources on preventing forced labor in your supply chain and moving toward supply chain transparency "from earth to hearth." 

Latest News

• Departments of State, Commerce, Homeland Security, Labor and the Treasury, and the Office of the U.S. Trade Representative updated advisory on Risks and Considerations for Businesses and Individuals with Exposure to Entities Engaged in Forced Labor and other Human Rights Abuses linked to Xinjiang, China (July 13, 2021)
• Commerce Department Adds Five Chinese Entities to the Entity List for Participating in China's Campaign of Forced Labor Against Muslims in Xinjiang (June 24, 2021)
• BIS Notice of Update to the Department of Labor's List of Goods Produced by Child Labor or Forced Labor (June 23, 2021)
• CBP issues Withhold Release Order on Chinese fishing fleet (May 28, 2021)

ST&R Forced Labor Approach

Importers should be taking affirmative steps to ensure compliance and manage risk. Our firm has developed the ST&R approach to address the focus on forced labor:

• Stocktaking of your existing corporate social responsibility programs and augmenting them with forced labor specific updates;
• Testing and Tracing your company and suppliers’ ability to respond to documentation requests and ensure the measures put in place are sufficient; and
• Responding, if necessary, to any potential CBP detention that may be issued.

Click here for a pdf describing our three-pronged approach in more detail. 

For a private consultation on your company's forced labor and supply chain visibility practices, please click here. 

Forced Labor Resources

• CBP's Withhold Release Order (WRO) List
• Bureau of Industry & Security (BIS) Entity List
• Office of Foreign Assets Control (OFAC)'s Specially Designated Nationals and Blocked Persons (SDN) Lists
• U.S. Department of Labor's List of Goods Produced by Child Labor or Forced Labor
• U.S. Department of Labor's List of Products Produced by Forced or Child Labor
• U.S. Department of State's Trafficking in Persons (TIP) Report
• CBP Forced Labor Page
• CBP Fact Sheet: Forced Labor - Points of Contact
• CBP Fact Sheet: Forced Labor - Importer Due Diligence
• CBP Fact Sheet: Forced Labor Detained Shipments
• United Nations Human Rights Council Joint Communication

Proposed Legislation on Forced Labor

Worldwide Actions to Prevent Forced Labor

Below, find actions taken worldwide to limit forced labor in the Xinjiang region. This list is not exhaustive.

• New EU guidance helps companies to combat forced labour in supply chains (July 13, 2021)
• Canada Border Services Agency: Memorandum D9-1-6 on Goods Manufactured or Produced by Prison or Forced Labour (May 7, 2021)
• Canada, UK, EU & the U.S. Working Together Over Human Rights (March 23, 2021) 
• Canada announces new measures to address human rights abuses in Xinjiang, China (January 12. 2021)
• UK Government announces business measures over Xinjiang human rights abuses (January 12, 2021)
• EU Parliament: Motion for a resolution on forced labour and the situation of the Uyghurs in the Xinjiang Uyghur Autonomous region (December 15, 2020)
• Australia's Modern Slavery Act (2018)