On September 5, 2024, the Department of Labor (DOL) released a revised version of its List of Goods Produced by Child Labor or Forced Labor. This 2024 report identifies the types of goods, the industries involved and the countries that the DOL has reason to believe are produced by child labor or forced labor in violation of international standards. The report is intended to assist foreign governments in developing effective policy responses, and to support U.S. businesses’ due diligence and risk management efforts in their supply chains.
The 2024 report includes 204 goods from 82 countries identified as likely produced by child labor or forced labor. This revised edition includes 72 new additions, including a “record” of 37 goods not previously included on the list. The report also includes several studies “tracing goods tainted with forced or child labor through complex global supply chains” and adds to the list 43 goods made with inputs that are produced with child labor or forced labor. DOL highlights that these goods include “cotton textile products from China and Vietnam produced with Chinese cotton, food and beverage products linked to child labor in cocoa industries in Ghana and Côte d’Ivoire and sugar products tied to forced labor in the sugarcane industry in the Dominican Republic.”
This edition of the report removes four items—blueberries from Argentina, salt from Cambodia, shrimp from Thailand, and fluorspar from Mongolia—as the DOL has determined that “child labor in these sectors and countries has been reduced to no more than isolated incidents.” As noted, however, 37 new goods have been added that have not been previously identified as having labor exploitation—including jujubes, lead, nickel, polyvinyl chloride, and squid—and identifies four new countries of concern: Belarus, the Netherlands, Mauritius, and South Korea. The DOL notes that the 2024 update “reveals the unsettling geographic span of labor exploitation, highlighting new additions from every region in the world, including 21 from African countries, 10 from the Western Hemisphere, and 8 from Europe.” Asia, particularly China, continues to have the most goods on the list.
In light of the fact that the Department of Homeland Security and U.S. Customs and Border Protection (CBP) are now fully enforcing the Uyghur Forced Labor Prevention Act (UFLPA) and detaining an increasing number of goods upon importation into the United States for review and possible enforcement actions, DOL’s 2024 report is a significant resource that U.S. importers should be referencing for conducting diligence into their suppliers and supply chains.