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A 'Record' 37 New Goods Identified for Potentially Involving Labor Exploitation: ILAB

The Department of Labor's Bureau of International Labor Affairs (ILAB) has 72 additions to its list of goods that could potentially be produced by forced labor or child labor, including a record 37 new goods that have not previously been identified as involving labor exploitation, ILAB said Sept. 5 in its latest edition of the List of Goods Produced by Child Labor or Forced Labor.

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This increase is "the largest number of both additions and removals of goods ever published" for the Trafficking Victims Protection Reauthorization Act (TVPRA) list, ILAB said.

The bureau attributed the increase in part to its funding of 15 projects since 2023 that traced goods across numerous industries and geographies. These projects included two $4 million projects to increase the downstream tracing of goods made by child labor and forced labor: Supply Chain Tracing and Engagement Methodologies (STREAMS) by Verité, which is conducting pilot projects in cotton and garment supply chains in India and developing a web-based Supply Chain Traceability Matrix; and Global Trace Protocol by Elevate, which is piloting open source traceability technologies and creating reports to map raw materials to the end product for Pakistan’s cotton and the Democratic Republic of the Congo’s cobalt supply chains, ILAB said.

The bureau is also publishing new supply chain research studies linking child labor and forced labor in key commodities to everyday items, ILAB said. "One study links aluminum made with the forced labor of Uyghurs and other mostly Muslim minorities in China’s Xinjiang region to auto parts made in China, while another examines widespread forced labor in the Dominican Republic’s sugarcane supply chain, highlighting the need to address these conditions as large quantities of sugar-based products are imported into the U.S."

Through all these studies and projects, ILAB identified 43 end products or downstream goods that might be tainted by child or forced labor.

Inputs that might have used child or forced labor, such as palm fruit from Malaysia and Indonesia or cobalt ore and copper ore from Congo, may eventually be involved in the production of downstream products, such as infant formula, cooking oils, pet food and cosmetic products for the palm oil, and cell phones, electric vehicles, medical implants and vacuums for the mineral ores.

Meanwhile, the 37 goods that have not been previously identified include jujubes, lead, nickel, polyvinyl chloride and squid. Four new countries were also added: Belarus, the Netherlands, Mauritius and South Korea.

"This year’s update reveals the unsettling geographic span of labor exploitation, highlighting new additions from every region in the world, including 21 from African countries, 10 from the Western Hemisphere, and 8 from Europe," ILAB said. "Asia stands out with the largest regional concentration with 33 additions from nine countries, underscoring the region’s central role in global supply chains. This includes 12 additions from China, where state-sponsored forced labor linked to the Xinjiang Uyghur Autonomous Region (Xinjiang) continues to impact major supply chains, and two additions from Burma, where workers experience egregious human rights violations under the military regime."

While the additional goods span across a number of industries, the mining and metallurgical sectors are "areas of concern," particularly because of their role in clean energy and national security, ILAB said.

"For the first time, the TVPRA List includes a good with multiple tainted inputs: lithium-ion batteries made in China are produced with two minerals from the Democratic Republic of the Congo -- copper mined with child labor and cobalt produced with child labor and forced labor," the bureau continued.

The full list includes 204 goods from 82 countries and areas. In addition to publishing the full list, ILAB also published the 23rd edition of the Findings on the Worst Forms of Child Labor.

In addition to publishing these reports, ILAB has updated tools and apps aimed at preventing forced labor and child labor, including a Sweat & Toil app, an online Better Trade Tool and ILAB's Comply Chain website.

Separately from ILAB's release of these reports, a Federal Register notice said ILAB is proposing to add garments from Bangladesh to the list of products requiring federal contractor certification that the goods were not produced using forced or child labor. It is also seeking comments on the likelihood that child labor or forced labor was involved in the production of shrimp from India and whether there are forced labor risks in gold supply chain inputs to the United Arab Emirates. ILAB is seeking comments through Dec. 16 on these items.

The bureau had announced Sept. 4 that it was removing two goods from its List of Products Requiring Federal Contractor Certification as to Forced or Indentured Child Labor: shrimp from Thailand and garments from Vietnam (see 2409040033).