Forced Labor

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On March 12th, the Office of the United States Trade Representative (USTR) initiated investigations under Section 301(b) of the Trade Act of 1974 of 60 countries for potential forced labor violations resulting in unfair competition for US companies selling abroad. According to U.S. Trade Representative Jameison Greer, the investigations will examine whether these…

On January 21, 2026, U.S. Customs and Border Protection (“CBP”) announced that its Forced Labor Portal is now live. This new online portal provides a single, centralized platform for importers to submit requests for review when their shipments are detained or excluded due to forced labor enforcement actions. By consolidating what was previously a patchwork…

On December 10th, 2025 the US Trade Representative released the results of the Section 301 investigation initiated in December 2024 into Nicaragua’s alleged violations of labor rights, human rights and the rule of law protections. The investigation detailed extensive infringement of labor and human rights in addition to increasingly authoritative restrictions of individual…

Camel Energy, a Michigan-based importer of lead-acid batteries, has recently filed a complaint at the Court of International Trade (CIT) contesting U.S. Customs and Border Protection’s (CBP) two recent exclusions of its shipments. CBP excluded these entries due to “suspicion of being made with forced labor and subject to the UFLPA.” Camel Energy maintains that…

On September 23, 2025, the U.S. Court of International Trade (CIT) issued an opinion vacating and remanding U.S. Customs and Border Protection’s forced labor Finding against Kingtom Aluminio S.R.L., a Dominican Republic-based aluminum extruder. The court found that CBP’s determination, which prohibited the entry of Kingtom’s aluminum extrusions under Section 307 of the Tariff Act…

On July 22, 2025, the U.S. Court of Appeals for the D.C. Circuit dismissed an action brought by eight Malian citizens against seven U.S. cocoa importers (Cargill, Nestlé, Mondelēz, Hershey, Olam, Barry Callebaut, and Mars) for forming and operating a cocoa supply chain to provide themselves with cheap cocoa harvested by child labor.  The action…

On June 20, 2025, U.S. Customs and Border Protection (“CBP”) deployed its new Forced Labor Allegations Portal, which allows users to submit allegations of forced labor. The new portal replaces CBP’s Trade Violations Reporting (“TVR”) system for submitting forced labor allegations, and complaints can be submitted anonymously by trade users. Users are also able…

The U.S. Department of Homeland Security (DHS) has announced the addition of 29 companies based in the People’s Republic of China (PRC) to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List.

The updated list now includes a total of 107 entities, with the newly added companies operating in the food processing and metals sectors.