- In September, the U.S. Department of Labor (DOL) published its two periodic signature reports on #child and #forced labour: List of Goods Produced by Child Labor or Forced Labor and Findings on the Worst Forms of Child Labor.? It also updated its List of Products Produced by Forced or Indentured Child Labor.
- The reports do not have legal standing in themselves, but they are key tools used by the U.S. government. The List of Goods Produced by Child Labor and Forced Labor is used by Congress in setting its strategy to monitor and target goods under the Tariff Act of 1930 – which bans the import of goods produced by forced or child labour – and under the Uyghur Forced Labor Prevention Act.? Findings on the Worst Forms of Child Labor is used to monitor a country’s eligibility for trade benefits under the U.S. Generalized System of Preferences.
- Freedom of association and collective bargaining are key focus points this year. Both reports include the same introduction, which highlights binding agreements, such as the Bangladesh Accord, as key solutions to identifying and tackling forced and child labour in supply chains. Additionally, for the first time, the Worst Forms of Child Labor Report includes a list of 29 countries where freedom of association and collective bargaining are restricted.
- The reports are critical of social audits in identifying forced or child labour. This is a key theme in the introduction to both reports and was also highlighted by the DOL in its webinar launching the reports.
- This year’s report has the most additions to the List of Goods Produced by Child Labor and Forced Labor compared to any other year. Two drivers appear to have contributed to this:
- New products were added following major NGO and media campaigns (e.g. see Mauritius, China, and India).
- While the 2022 report began to include downstream products, this is a significantly greater focus in 2024. 59% of the newly listed products are downstream goods, meaning they are produced using inputs made with forced or child labour. Since 2023, ILAB has funded 15 projects to identify and trace goods made with forced labour in global supply chains. This includes two U.S.$ 4 million projects—one led by Verité, which examined the cotton and garment supply chains in India, and another by ELEVATE, which focused on Pakistan’s cotton and the Democratic Republic of Congo’s cobalt supply chains.
- For brands, these reports highlight foreseeable risks of forced and child labor and regulators will expect brands to be aware of these risks. We recommend that clients integrate the findings into their global risk assessments and double materiality processes under the #CSDDD and #CSRD and ensure that strategies are in place to address child and forced labour when sourcing from listed countries.
Find a detailed analysis of the key themes and implications of each report on our website
