Overview
I. Introduction
Forced labor trade enforcement is no longer a two-jurisdiction story. For nearly a century, the United States stood essentially alone in prohibiting the import of goods made with forced labor; the European Union will join in December 2027. In a companion analysis, we examined the guidance documents that US Customs and Border Protection (CBP) and the European Commission issued within weeks of each other this summer—and the distinct visions of compliance they reflect: documentary proof at the border versus governance-based human rights due diligence. This piece addresses the next phase, which arrived last week. On July 24, 2026, the USUSTR's final action in its Section 301 forced labor investigations took effect, imposing additional duties of 10% or 12.5% on 60 economies—more than 80 countries, accounting for over 99% of US imports—for failing to adopt or effectively enforce forced labor import bans of their own. Forced labor import prohibitions are now proliferating across the trading system at remarkable speed. Below, we survey the new laws, propose a working typology of their legislative approaches, and identify the practical steps companies should be taking now to prepare for a world of many enforcers.
II. The US–EU Baseline
By way of brief summary: the United States enforces three interlocking authorities—Section 307 of the Tariff Act of 1930, the Uyghur Forced Labor Prevention Act (UFLPA), and CAATSA1—consolidated for the first time in CBP's June 9, 2026 Forced Labor Enforcement Operational Guidance for Importers. The EU Forced Labor Regulation (EUFLR), applying from December 14, 2027, prohibits placing on, making available in, or exporting from the EU market any product made with forced labor; the European Commission published its implementation guidelines on June 26, 2026. In addition, USTR determined on June 2, 2026 that all 60 investigated economies had failed to impose—or, in six cases, to effectively enforce—a forced labor import prohibition.2 The final action, announced July 23 and effective July 24, 2026, calibrates the duty to each economy's progress: seventeen economies—Canada, Mexico, India, and the UK among them—pay a flat 10%; the EU and Taiwan pay 10% net of MFN duties; Japan, South Korea, and Switzerland 12.5% net of MFN; and the remaining 38, including China, a flat 12.5%. (NB: the action is subject to a legal challenge filed within hours of entry into force, which contends that USTR exceeded Section 301's country-specific findings and remedial requirements.)
III. The Proliferation
To the extent the s.301 investigations were designed to catalyze legislation abroad, they have succeeded. Since March, at least fourteen jurisdictions have adopted new forced labor import prohibitions. Pakistan amended its Import Policy Order, 2022, to bar imports of goods mined, produced, or manufactured with forced labor, irrespective of origin; importers must provide verifiable proof that goods are forced-labor free, with high-risk goods, entities, and countries designated by reference to ILO determinations.3 Indonesia issued a trade-ministry regulation prohibiting the import of goods produced with forced labor. Cambodia—whose interministerial regulation (Prakas No. 45) took effect July 1, 20264—Guatemala, El Salvador, Nicaragua, and Ecuador have adopted analogous customs prohibitions. In its final action, USTR recognized Cambodia, Guatemala, Honduras, India, Sri Lanka, and Trinidad and Tobago as having imposed prohibitions of their own—a recognition that, in India's case, earned placement in the 10% tier. And the tariffs' entry into force has triggered a further wave: within days, the Dominican Republic issued Decree No. 502-26 empowering its customs agency to seize goods linked to forced labor; Israel's Cabinet approved a prohibition on imports made wholly or in part with forced labor; and Taiwan established a cross-agency review mechanism under its Foreign Trade Act to block such goods, converting its trade-agreement commitment into an operating regime.
These newcomers join an existing cohort. Canada has prohibited forced labor imports under its Customs Tariff since 2020, supplemented since 2024 by supply chain reporting legislation—and, on June 12, 2026, by the introduction of Bill C-35, standalone legislation to strengthen the import ban.[5] Mexico's 2023 regulation implementing USMCA Article 23.6, administered by its labor ministry, was amended in late 2025 to close procedural gaps that had left the prohibition largely nominal, though no investigation under the amended regime has yet been publicized.6 And in the United Kingdom, both the Joint Committee on Human Rights and the Independent Anti-Slavery Commissioner have called for legislation combining an import ban, mandatory due diligence, and civil liability. Argentina, Bangladesh, Malaysia, and Jordan, among others, have committed to adopt prohibitions through Agreements on Reciprocal Trade with the United States. The direction of travel is unmistakable: likely within a few years, many, if not most, major trading economies will maintain some form of forced labor import prohibition.
IV. A Working Typology
The new regimes are not cut from a single cloth. Three legislative approaches are emerging, with enforcement contemplated by three types of governmental authorities.
The proactive declaration model. Nicaragua7 and El Salvador require importers to affirmatively declare or certify at entry that goods are free of forced labor and provide key details and supporting documents associated with the shipments, with authorities empowered to require supplementary documentation where doubts arise—a proactive obligation attaching to every shipment, though a thin one until verification practices develop.
The notified-goods model. Pakistan attaches an affirmative documentary burden not to every shipment but to goods, entities, and source countries designated by government notification anchored to ILO determinations (none of which has yet issued). Canada's Bill C-35 proposes the same risk-based architecture: a ministerial list of high-risk goods, prescribed supply chain information for listed goods, and shipments deemed prohibited where that information is not provided. This listing-and-disclosure design—functionally a targeted reverse onus—is the closest relative of the UFLPA's presumption mechanism, and the logic that may prove most attractive to other enforcement authorities.
The investigation-led model. Indonesia obliges importers to ensure their goods are free of forced labor, but enforcement runs through an inter-ministerial investigation, and only goods proven through that process to have been made with forced labor are barred at the border by customs.8 Mexico's labor-ministry-administered regime shares this design, but the EUFLR is its fullest expression: the burden of proof rests with authorities, due diligence functions as an investigative shield, and remediation—not merely re-sourcing—is required before banned products return to the market.
Cutting across all three approaches is the question of risk designation: the United States relies on domestic instruments (the UFLPA Entity List and Withhold Release Orders); the EU is building a centralized risk database; Pakistan outsources designation to the ILO; and Indonesia relies on reporting from the public or government agencies. Where a jurisdiction anchors its list determines both the predictability of enforcement and the leverage points available to companies, although it is all but certain that the United States will exert at least some pressure on its trading partners to address those products, entities and sectors the US itself has designated—indeed, the continued entry of goods the United States itself had barred formed part of USTR's evidentiary case on Canada's and Mexico's enforcement failure.9 The deeper caveat is enforcement: USTR's final action found that all six economies with pre-existing prohibitions—Canada, Ecuador, the EU, Indonesia, Mexico, and Pakistan—had failed to enforce them effectively, and none of this year's adopters has yet built an enforcement record. The typology describes statutory design, not demonstrated practice, which remains an open question.
V. Preparing for Many Enforcers: Two Foundational Moves
Proliferation does not require companies to build a compliance program per jurisdiction. It requires a single program engineered to the most demanding standards with certain core components. Two moves matter most.
1) Build one prioritized due diligence program with the US and EU as its spine.
The two reference regimes define the outer bounds of what any enforcer will demand: CBP's guidance sets the documentary ceiling—raw-material traceability and chain-of-custody records; country-of-origin documentation such as certificates of origin; transportation records such as bills of lading; and pricing substantiation—invoices and purchase orders showing commercially reasonable pricing, proof of payment at that pricing, and supply chain screening (via Sayari, Altana, or equivalent tools) free of unexplained red flags—while the Commission's guidelines and the mandatory due diligence regimes (the CS3D, Germany's LkSG, and Canada's promised legislation) define the governance baseline of policies, risk assessment, stakeholder engagement, monitoring, and remediation. The US Department of Labor's SourcingStrong framework—an eight-step, all-sector self-assessment tool—offers a useful integration scaffold, not least because it sequences worker and stakeholder engagement first. A program built to that combined standard will satisfy the proliferating national regimes at marginal cost, since none demands more than the union of the two models.
Prioritization within the program should run on two axes: (i) risk of harm—the severity and likelihood of forced labor in a given supply chain, by commodity, geography, and production method; and (ii) value-chain exposure, including demonstrated and announced regulator priorities (the UFLPA Entity List and Withhold Release Orders, the TVPRA list, the EU risk database, and the notified-goods lists now emerging in national regimes), sourcing volumes, criticality, and substitutability. The intersection of these criteria would help drive principled and practical priority tiers where full traceability is warranted; strategic depth there, rather than uniform shallow coverage, is the objective. Documentary rigor of this kind serves a second function in certification-model jurisdictions such as Nicaragua and El Salvador: it gives the personnel and brokers who sign and submit import declarations a supportable evidentiary basis for their attestations—meaningful protection where declarations carry personal exposure and rule-of-law safeguards are weak.
2) Maintain a crisis-response handbook with modular jurisdictional coverage.
Given the pervasiveness of forced labor across global supply chains, with virtually no sector or geography immune, every company will also need to prepare proactively for possible enforcement actions by distinct authorities. The core modules should address the US and EU: for the US, the UFLPA's 30-day response window, the showing that goods have no ties to Xinjiang or listed entities—the route through which every release to date has come, no importer having yet satisfied the clear-and-convincing exception standard—and Withhold Release Order and Finding procedures; for the EU, the EUFLR's two-tier investigation process, including the "facts available" rule—retained in the Commission's June 2026 guidelines—under which non-cooperation itself constitutes in principle evidence sufficient to establish a violation.10 To these, companies should add jurisdiction-specific modules as their sourcing and market footprint dictates—and as regimes become operational: monitoring, for example, Pakistan's forthcoming ILO-based notifications and the progress of Canada's Bill C-35 as triggers, rather than building out procedures for regimes that have yet to enforce. Each module should designate response leads, map documentary readiness against the shortest applicable clock, define escalation and communication protocols, and pre-position rebuttal strategy with counsel retained. The handbook should be tabletop-tested and refreshed as the sourcing footprint changes.
VI. Conclusion
The forced labor enforcement map is being redrawn in real time. What began as an American anomaly is becoming the trading system's default setting, with the EU's governance-inflected variant close behind and national regimes now taking root between the two. Companies that anchor a single, prioritized program to the US documentary standard and the EU governance standard—and keep a modular crisis-response capability current—will find that each new national ban demands little more than a supplement. Those that wait will be building the program under detention deadlines rather than ahead of them.
2 Initiation of Section 301 Investigations of Acts, Policies, and Practices of Various Economies Related to the Failure To Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced With Forced Labor, 91 Fed. Reg. 12,884 (Mar. 17, 2026).
4 Interministerial Regulation (Prakas) No. 45 on the Prohibition on Imports of Goods Linked to Forced Labor (July 1, 2026) (Cambodia).
5 Customs Tariff, S.C. 1997, c. 36, sch., tariff item No. 9897.00.00 (Can.); Fighting Against Forced Labour and Child Labour in Supply Chains Act, S.C. 2023, c. 9 (Can.); Bill C-35, An Act Respecting the Prohibition of the Importation of Goods Produced by Forced Labour, 1st Sess., 45th Parl. (Can.) (first reading June 12, 2026).
6 Acuerdo que establece las mercancías cuya importación está sujeta a regulación a cargo de la Secretaría del Trabajo y Previsión Social, Diario Oficial de la Federación (Feb. 17, 2023) (Mex.) (effective May 18, 2023), modified by Acuerdo of Oct. 29, 2025, Diario Oficial de la Federación (Mex.).
8 Minister of Trade Regulation No. 9 of 2026, arts. 5–6 (Indon.).
10 European Commission, Guidelines on the Application of Regulation (EU) 2024/3015 on Prohibiting Products Made with Forced Labour on the Union Market, C(2026) 4386 final, §§ 4.8.2–4.8.2.1 (June 26, 2026).
