U.S. Customs and Border Protection has been running year-long investigations into forced and child labor. The agency publicly stated it has been acting on information concerning specific manufacturers/exporters and specific merchandise and was not targeting entire product lines or industries in suspect countries or regions.

However, in practice it has recently come to light that the agency has issued questionnaires to certain industries related to their production in countries named on the Department of Labor’s website as those that use child or forced labor in their production of certain goods.

As of September 30, 2016, the list of goods produced by child labor or forced labor comprises 139 goods from 75 countries. If there is forced labor in any portion of a company’s supply chain, these goods may be excluded from importation into the United States.

Companies should closely examine their supply chains to ensure that goods imported into the U.S. are not mined, produced or manufactured, wholly or in part, with prohibited forms of labor, i.e., slave, convict, forced child, or indentured labor.

For more information, contact: Frances Hadfield