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U.S. Expands Forced Labor Enforcement Strategy and Adds New High-Risk Sectors

 -Editorial

The U.S. government has unveiled a significant expansion of its efforts to block goods made with forced labor from entering the American marketplace, with a particular focus on products originating from China. The Forced Labor Enforcement Task Force, led by the Department of Homeland Security (DHS) in coordination with the Department of Labor and other agencies, announced an updated 2025 strategy to strengthen enforcement of the Uyghur Forced Labor Prevention Act (UFLPA).

The new enforcement framework, officials said, is designed to help U.S. Customs and Border Protection (CBP) more effectively identify and stop shipments suspected of being linked to forced labor, particularly in China’s Xinjiang Uyghur Autonomous Region. The UFLPA, enacted in 2021 with bipartisan support, establishes a rebuttable presumption that goods produced in Xinjiang, or by companies on the UFLPA Entity List, are made with forced labor and therefore prohibited from entering the U.S.

The 2025 update revises the UFLPA Entity List to include 144 foreign companies and organizations that are barred from importing into the U.S. due to suspected ties to forced labor practices. The Department of Labor’s Bureau of International Labor Affairs (ILAB) plays a central role in maintaining this list, conducting research, gathering evidence, and evaluating whether companies meet the criteria for designation.

By expanding the list, U.S. authorities aim to put greater pressure on foreign companies and encourage American businesses to conduct more rigorous supply chain due diligence. “America First means keeping foreign goods made with forced labor off our shelves and ensuring American businesses aren’t put at a disadvantage,” said U.S. Secretary of Labor Lori Chavez-DeRemer in a statement.

The revised strategy also identifies five additional high-risk sectors where forced labor is considered a growing concern: caustic soda, jujubes, copper, lithium, and steel. These sectors join an existing list that already included cotton, electronics, tomatoes, and other goods flagged under UFLPA, bringing the total number of “high-priority sectors” to 13.

Officials said the new designations were based on evidence from labor reports and global supply chain research. China is currently the world’s leading producer of both caustic soda, a chemical used widely in manufacturing, and jujubes, a fruit linked to labor exploitation. Both products also appear on the Labor Department’s List of Goods Produced by Child Labor or Forced Labor.

The announcement coincided with the release of the 11th edition of the List of Goods Produced by Child Labor or Forced Labor, a biennial report mandated under the Trafficking Victims Protection Reauthorization Act (TVPRA). The 2024 edition marked the largest expansion in the history of the list, adding 72 goods and removing four.

In total, the report identifies 204 goods from 82 countries and regions. China is the country with the highest number of goods associated with forced labor—31 in all, with 21 linked specifically to forced labor in Xinjiang. These include aluminum, caustic soda, polyvinyl chloride, squid, and jujubes.

The report is widely used by businesses, governments, civil society groups, and consumers as a resource to understand global labor risks. It serves as a roadmap for developing laws, strengthening corporate supply chain due diligence, and promoting responsible sourcing.

The updated enforcement measures come amid ongoing concerns about the use of forced labor in Xinjiang, where human rights groups and U.S. officials have documented widespread abuses against Uyghurs and other Muslim minorities. Beijing has denied allegations of forced labor, but U.S. lawmakers and agencies have repeatedly cited evidence that workers are coerced into labor under state-backed programs.

The new UFLPA strategy reflects a growing international push for corporate accountability. In addition to U.S. measures, the European Union is advancing its Corporate Sustainability Due Diligence Directive (EU CSDDD), which would require European companies to identify and address human rights risks in their supply chains.

By strengthening enforcement, U.S. officials say they are protecting not only workers abroad but also ensuring fair competition at home.

In recent years, ILAB has increased funding for projects aimed at tracing goods across global supply chains, a critical step in identifying forced labor. Since 2023, the department has supported 15 research projects that map raw materials to finished products, from cobalt in the Democratic Republic of the Congo to cotton in South Asia.

One study traced aluminum made with Uyghur forced labor in Xinjiang to auto parts exported worldwide. Another examined forced labor in the Dominican Republic’s sugarcane sector, linking it to processed sugar and rum imported into the U.S. These findings, officials said, highlight the challenges of modern supply chains and the importance of transparency.

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