Global Forced Labor Enforcement Is Converging Around Human Rights Due Diligence

By Elizabeth Fay
Senior Director, Policy Advocacy

Forced labor import bans are expanding across markets, and companies are increasingly asking what this means in practice. The priority now is preparation, not panic. Companies that are steadily building strong human rights due diligence systems—mapping their supply chains, identifying risks, acting on findings, and documenting what they are doing—will be better positioned to respond as enforcement expectations grow.

Two recent developments reflect the continued global expansion of forced labor import bans as a trade enforcement mechanism, reinforcing a trend Verité has tracked for several years: effective compliance increasingly depends on human rights due diligence. In practice, companies cannot credibly show that their goods are free from forced labor risks unless they have systems in place to understand their supply chains, identify risks, address harms, and document what they have done.

First, the United States Trade Representative (USTR) recently announced the next phase of its Section 301 investigations, targeting 60 trading partners that have not adopted or effectively enforced prohibitions on imports of goods produced with forced labor. Under the proposed action, economies that have adopted—or committed to implementing and enforcing—forced labor import bans would face lower tariffs, while those that have not would face higher duties.

Since the launch of the investigations, U.S. trading partners have signaled varying levels of commitment. Some have strengthened national labor laws, while others have committed to adopting and enforcing forced labor import prohibitions.

If authorities have a substantiated concern that forced labor may be linked to a product, companies should be prepared to show what they have done to identify, prevent, mitigate, bring to an end or remediate related risks.

The second major development is in the European Union (EU). The EU recently issued guidance on how companies should cooperate with competent authorities when forced labor investigations are initiated under the European Union Forced Labour Regulation (EUFLR). This guidance is an important step toward the Regulation’s full implementation in December 2027.

The guidance clarifies company obligations under the Regulation’s prohibition on placing, making available, or exporting goods made with forced labor on or from the Union market. If authorities have a substantiated concern that forced labor may be linked to a product, companies should be prepared to show what they have done to identify, prevent, mitigate, bring to an end or remediate related risks.

Taken together, these developments signal a clear trend: forced labor trade enforcement is scaling across jurisdictions, and authorities increasingly expect companies to demonstrate robust, systematic approaches to identifying and addressing forced labor risks in their supply chains.

The Common Threads Across Import Bans

Verité’s comparative analysis of forced labor import bans reveals a notable pattern. These laws generally do not tell companies they must conduct human rights due diligence. Instead, they set an outcome-based standard: goods made with forced labor should not enter the market.

That outcome is difficult to achieve without due diligence.

Companies cannot reliably ensure compliance—or credibly respond to enforcement actions—without systems that generate the information, traceability, oversight, and corrective action processes associated with human rights due diligence.

Across jurisdictions that have adopted, implemented, or are currently implementing forced labor import bans, several common themes have emerged:

• Enforcement guidance is becoming increasingly specific regarding the evidence companies should maintain and produce to demonstrate that they have identified, mitigated, remediated, and prevented labor rights abuses.
• Enforcement authorities increasingly encourage companies to look to the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the OECD Due Diligence Guidance for Responsible Business Conduct when developing their compliance programs.
• The ILO Indicators of Forced Labour have become central to investigations and enforcement, serving both as indicators of potential forced labor and as guideposts for the risks companies are expected to identify and address.
• The definition of forced labor contained in ILO Convention 29 remains the foundational standard across regulatory regimes.

This graphic is based on the European Commission’s guidance under the EU Forced Labour Regulation published June 2026. The new EUFLR guidance outlines indicative types of evidence companies may provide during an investigation to demonstrate how they address these forced labor risks. We have mapped this evidence against the stages of due diligence. Click here to open a larger version of the above graphic.

What Evidence May Matter in an EUFLR Investigation

When forced labor import prohibitions are enforced and investigations are launched, companies are expected to cooperate with enforcement authorities by providing information related to the products under investigation. In practice, this means providing information about the products under investigation and the steps the company has taken to address forced labor risks.

Much of this information is the same documentation that should be generated through standard human rights due diligence. This may include supply chain mapping, risk assessments, records of supplier engagement, corrective action plans, remediation efforts, and documentation of steps taken to prevent risks from recurring.

New guidance under the EU Forced Labour Regulation illustrates this approach, clarifying how companies should cooperate with competent authorities during investigations triggered by substantiated concerns that products were made with forced labor. It includes types of evidence companies may submit to show how they have identified, prevented, mitigated, brought to an end or remediated forced labor risks related to the product under investigation.

While the Regulation does not introduce any new due diligence requirements, the new EUFLR guidance includes an indicative list of the types of evidence a company may provide during the investigation to demonstrate knowledge of its supply chain for the product under review and its efforts to identify, prevent, mitigate, bring to an end, or remediate risks of forced labor. The accompanying Verité graphic maps this evidence against the key stages of the OECD due diligence framework. This reinforces a broader point: companies that build due diligence systems aligned with international standards will be better prepared to respond to enforcement inquiries across markets.

As forced labor import bans expand and enforcement deepens, authorities are converging around a common expectation: companies must be able to demonstrate how they identify, address, and prevent labor risks in their supply chains.

U.S. enforcement practice reflects a similar shift. Recent U.S. Customs and Border Protection Forced Labor Enforcement Operational Guidance for Importers, makes clear that remediation of harms alone is insufficient. Beyond addressing identified harms, companies are increasingly expected to demonstrate credible due diligence systems capable of identifying, assessing, and mitigating forced labor risks across their supply chains. Enforcement authorities also want to see that companies have systems in place—or credible commitments to build them—to prevent the recurrence of forced labor risks. This is becoming a core condition for continued market access.

The direction of travel is clear. As forced labor import bans expand and enforcement deepens, authorities are converging around a common expectation: companies must be able to demonstrate how they identify, address, and prevent labor risks in their supply chains.

International standards—including the UN Guiding Principles, OECD Due Diligence Guidance, and ILO standards and indicators on forced labor—are emerging as the connective tissue across these approaches. As prohibitions on goods made with forced labor continue to gain traction across jurisdictions, anchoring compliance in these frameworks provides companies with a clear “north star” for developing consistent and credible approaches to compliance across markets.

About the author

Elizabeth Fay is Senior Director of Policy Advocacy at Verité, bringing over 25 years of experience working across the private and public sectors. With more than 15 years at one of the world’s largest agricultural and food companies and a decade as a legislative advisor in the U.S. Senate, she has focused on the intersection of labor, human rights, and international development to support responsible business growth. At Verité, she leads advocacy to shape government policies that promote fair, safe, and legal working conditions in global supply chains.