By Quinn Kepes : Senior Regional Lead, Americas
Last week, U.S. Customs and Border Protection issued a Withhold Release Order (WRO) against coffee from a Mexican coffee farm. This means that effective immediately, CBP will detain any coffee from this farm at all U.S. ports of entry.
For coffee companies, the action is a stark reminder that forced labor import bans are no longer theoretical. Enforcement is real, and it is reaching deeper into agricultural supply chains, including coffee.
As governments move to active enforcement of forced labor import bans, coffee companies are under growing pressure to understand where the highest labor risks sit in their supply chains. Yet one of the most persistent challenges in the sector is a lack of reliable, comparable data across origins.
This question came up directly during a recent Verité webinar, Navigating Legal Risks and Import Bans in the Coffee Sector:
“The coffee sector is light on documentation—are there indications of where risk is highest and how it shows up?”
The answer reveals a critical truth: in coffee, the countries for which there is the most data on forced labor risks are not always the places with the actual level of risk is highest.
When More Data Does Not Mean More Risk
Some coffee origins appear frequently in forced labor adverse media scans because there is more government data, published research and media coverage. Brazil is a good example. There is extensive documentation on forced labor in Brazilian agriculture, including public inspections data, the ‘Dirty List,’ active civil society monitoring, and sustained press coverage.
But this does not necessarily mean that working conditions in Brazil are worse than in other coffee-producing countries.
Brazil has the systems in place to detect and expose abuse: labor inspections, transparent reporting, government action, and active watchdog organizations. Risk is visible because there are mechanisms to surface it.
In many other origins, those systems simply do not exist.
Across parts of Latin America and beyond, there are countries with virtually no published research on forced labor in coffee. There may be no government inspections, no reporting, no remediation programs, and limited civil society engagement. In these contexts, forced labor indicators can be just as severe—or worse—but remain hidden.
When abuse goes uninspected and unaddressed, it continues in the dark.
The recent WRO on Mexican coffee is a perfect example of how this can result in legal and reputational risk. The enforcement action was unexpected; very little information had been published on forced labor risks in the Mexican coffee sector and there had been no obvious signal that a WRO was forthcoming. Now unprepared companies must race to determine how to respond.
The Limits of Desk-Based Risk Screening
This reality has serious implications for due diligence.
Desk-based risk screenings that rely only on published reports and secondary data can be deeply misleading. Companies may end up directing resources toward origins where risks are already visible and being addressed, while overlooking higher-risk regions where no data exists precisely because abuses remain hidden.
That misalignment matters more than ever.
U.S. Customs and Border Protection is increasingly proactive in doing forced labor investigations and countries in the European Union will soon be receiving petitions, launching investigations, and enforcing its new forced labor import ban and due diligence requirements. Regulators are not relying solely on published reports—they are looking for evidence of real-world conditions and credible risk management systems.
For companies, understanding where risks are truly highest in their supply chains is no longer optional. It is a legal and operational necessity.
Why Worker-Informed Research Is Essential
Verité’s field research across coffee origins has consistently shown that forced labor risk is widespread —and in many cases worsening—even years after initial studies were published. These patterns reflect broader dynamics in the coffee sector, including labor shortages, recruitment practices, piece-rate payment systems, and migrant worker vulnerabilities.
This is why relying on desk research alone can miss the mark.
Worker-informed, field-based research sheds light on poorly understood problems by amplifying workers’ voices and centering their lived experiences. It allows companies to see beyond what is visible in reports and to identify risks that authorities are increasingly targeting.
Resources for Companies Seeking Deeper Insight
To support companies navigating these challenges, Verité has developed a range of open-access tools and resources relevant to the coffee sector, including:
- The COFFEE Toolkit, with practical tools, resources and training videos in English, Spanish, and Portuguese for companies, traders, and farmers.
- Recent white papers on piece-rate pay and on recruitment, labor migration, and labor shortages, which examine key root causes of forced labor risk in coffee
- The Farm Labor Due Diligence Toolkit, a comprehensive resource to help companies tackle challenging human rights issues in agricultural supply chains, including in the first mile.
- Detailed report on forced labor indicators in the Guatemalan coffee sector, which remains relevant today
- Webinar recording: Forced Labor Enforcement is Brewing: Navigating Legal Risks and Import Bans in the Coffee Sector
These resources are grounded in independent, worker-centered research and are designed to illuminate labor risks, helping companies move beyond surface-level screening. For companies seeking tailored support, our human rights due diligence consulting helps translate these insights into practical, operational action.
About the Author
Quinn Kepes serves as Verité’s Senior Regional Lead for the Americas, bringing over 19 years of experience supporting businesses, investors, governments, intergovernmental organizations, and civil society with research-driven tools and insights to address labor and human rights risks in global supply chains. He leads Verité’s regional programming to identify, prevent, and address child labor, forced labor, and other critical labor challenges through desk and field research, project implementation, and Human Rights Due Diligence implementation. He has worked in the coffee sector for over 15 years, including leading research and projects in Mexico, Guatemala, Honduras, Costa Rica, Panama, Colombia, Brazil, and Uganda.
