Expanding Public Manifest Access Could Help Ferret Out Forced Labor, Murphy Says
Expanding access to manifest data from sources to include air cargo manifests and other transportation modes could provide the public and trade stakeholders with greater ability to ferret out forced labor in the supply chain, said Laura Murphy, senior associate with the Center for Strategic and International Studies' Human Rights Initiative, in a Dec. 8 blog post.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
Currently, U.S. law allows for U.S. customs records, or shipping manifests, from ocean vessels to be available to the public, enabling businesses and other interests to use this data to examine supply chains and find instances of forced labor, according to Murphy, a forced labor researcher and former adviser to DHS. But a bill introduced by Sen. Bill Cassidy, R-La., in April, the Manifest Modernization Act, would amend the Tariff Act of 1930 to require the public disclosure of manifest information from aircraft and potentially other transportation modes.
Cassidy also introduced a separate bill this past spring that sought to create a true single window for importers, as well as reduce redundancies in advance export manifest data submissions (see 2503110078).
"The public availability of customs data has significantly enhanced the CBP’s capacity to target illicit goods by empowering civil society, academics, media, and other stakeholders to analyze and publish information that leads to necessary enforcement action," Murphy said. "But despite the clear advantages of publishing customs records, the United States only makes a limited segment of customs data available to the public, leaving large swathes of trade activity invisible. Expanding access to customs records will increase the United States’ (and other countries’) ability to identify imports of forced-labor-made goods and protect legitimate international trade."
Under the current system, a lack of publicly available data on cargo that's not shipped by ocean vessel "leaves a significant blind spot," Murphy said, pointing to a May 2025 CBP update saying that imports arriving by sea account for only 38% of total import value.
But having access to manifest data from air and land cargo sources could better allow groups to track potential forced labor situations, as well as bolster coordination under the USMCA to identify cross-border movement of goods made with forced labor, she continued.
While there has been pushback from some in the industry over concerns that the data disclosures could compromise business confidential information or be too burdensome, this pushback is "misplaced," as the bill would enable all imports to "be transparent, ensuring fair competition, which could reduce consumer costs and increase corporations’ ability to identify suppliers that are compliant with U.S. law," Murphy said.
The bill also could support U.S. calls for increased trade security, according to Murphy, and create ripple effects across global trade.
"The ocean vessel manifest data disclosed under the current law has been critical in uncovering myriad trade violations -- not only forced labor, but also counterfeits, illegal transshipment and dumping, sanctions evasion, and illicit drug trafficking. Furthermore, companies can use this data to more accurately trace their own supply chains and identify risky suppliers," Murphy said. "By making air, rail, and road transport data publicly available, the U.S. government will eliminate the risk of bad actors using those means to hide their shipments from public scrutiny."