ARTICLE
25 June 2025

Navigating Forced Labor Trade Regulation

SJ
Steptoe LLP

Contributor

In more than 100 years of practice, Steptoe has earned an international reputation for vigorous representation of clients before governmental agencies, successful advocacy in litigation and arbitration, and creative and practical advice in structuring business transactions. Steptoe has more than 500 lawyers and professional staff across the US, Europe and Asia.
Forced labor – work extracted through coercion, fraud, or menace of penalty – is one of the most prevalent and severe human rights risks in global supply chains.
United States Government, Public Sector

Abstract

Forced labor – work extracted through coercion, fraud, or menace of penalty – is one of the most prevalent and severe human rights risks in global supply chains. It is also an increasing regulatory and litigation risk for business. While much attention has been paid to emerging due diligence, disclosure, and civil liability regimes, the most complex arena for companies to navigate is arguably trade regulation. This piece focuses on three forced labor-related trade measures: Section 307 of the US Tariff Act; the Uyghur Forced Labor Prevention Act; and the EU Forced Labour Regulation. We compare the scope, enforcement, and sanctions regimes and explain some notable implications for business.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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