Recent Trade Actions by US Government Signal Renewed Focus on Forced Labor

Recent actions by US Customs and Border Protection, the Office of the United States Trade Representative, and the White House suggest that forced labor enforcement is reemerging as a significant trade compliance priority. While public detention statistics under the Uyghur Forced Labor Prevention Act appeared comparatively subdued over the last year, June 2026 brought multiple developments that collectively signal a renewed emphasis on identifying, detaining, and restricting imports linked to forced labor.

The developments include three new US Customs and Border Protection (CBP) Withhold Release Orders (WROs), the release of comprehensive forced labor operational guidance for importers, a new executive order directing federal agencies to prioritize forced labor enforcement, and United States Trade Representative (USTR) findings against 60 economies under Section 301 of the Trade Act of 1974 relating to failures to prohibit and effectively prevent trade in goods produced with forced labor.

Together, these actions suggest that companies with global and complex supply chains should closely monitor forced labor developments and evaluate whether their existing compliance and supply chain due diligence programs are sufficient for a potentially more active enforcement environment.

Key Takeaways

• CBP issued three new WROs in June 2026 targeting copper products from Serbia and garments produced in Jordan.
• CBP’s new Forced Labor Enforcement Operational Guidance provides importers with detailed insight into CBP’s detention, exclusion, and admissibility review processes; enhanced documentation expectations; and steps to mitigate forced labor risks in global supply chains.
• A new customs enforcement executive order expressly identifies forced labor imports as a federal enforcement priority.
• USTR has proposed new Section 301 tariffs tied to foreign governments’ failures to prohibit and effectively enforce restrictions on imports of goods produced with forced labor.
• Companies with global supply chains should reassess forced labor compliance programs, supply chain visibility, and documentation readiness.

CBP ISSUES THREE NEW WITHHOLD RELEASE ORDERS

In June 2026, CBP issued three new WROs under 19 USC § 1307, which prohibits the importation of goods produced wholly or in part with forced labor. A WRO allows CBP to detain the product(s) in question at all US ports of entry unless importers can prove the absence of forced labor in their product’s supply chain.

On June 16, CBP issued a WRO covering copper and copper products manufactured by Serbia Zijin Copper DOO in Serbia. One week later, CBP issued two additional WROs covering garments produced by Needle Craft Ltd. and Casual Wear Apparel LLC in Jordan.  

These WROs represent CBP’s fourth, fifth, and sixth WROs of fiscal year 2026. The actions are notable not only because they expand the list of active WROs, but also because they target products and jurisdictions outside the Xinjiang-focused enforcement activity that has dominated forced labor discussions in the past several years.

CBP RELEASES NEW FORCED LABOR OPERATIONAL GUIDANCE FOR IMPORTERS

On June 12, CBP published its new Forced Labor Enforcement Operational Guidance for Importers, a comprehensive document designed to consolidate and explain the agency’s forced labor enforcement authorities and procedures.

The guidance provides a detailed overview of the three principal authorities CBP uses to prevent the importation of goods produced with forced labor:

• Section 307 of the Tariff Act of 1930 (19 USC § 1307), including WROs and Findings
• The Uyghur Forced Labor Prevention Act (UFLPA)
• The Countering America’s Adversaries Through Sanctions Act (CAATSA)

The guidance includes process maps and step-by-step explanations describing what importers can expect when shipments are detained, excluded, or otherwise subjected to forced labor review. It also provides sample notices, documentation expectations, due diligence examples, and extensive appendices describing supply chain tracing expectations for high-priority sectors.

Perhaps most importantly, the guidance offers importers a detailed view into the types of records and documentation CBP expects companies to maintain to demonstrate supply chain traceability and admissibility. The document emphasizes supply chain mapping, supplier engagement, traceability to the raw material level, and the maintenance of records sufficient to demonstrate that imported goods are not produced wholly or in part with forced labor. \

CBP also highlights the benefits that importer participation in the Customs Trade Partnership Against Terrorism (CTPAT) can provide for forced labor reviews, including prioritized admissibility review, flexibility for redelivery from importer facilities, preliminary hold notifications, and advance notice of WROs or findings.

The publication of the consolidated forced labor guidance provides importers with greater transparency into CBP’s enforcement expectations while also signaling the agency’s continued focus on supply chain due diligence and documentation.

NEW CUSTOMS EXECUTIVE ORDER ELEVATES FORCED LABOR ENFORCEMENT

The White House further reinforced the importance of forced labor enforcement through Executive Order 14411, Strengthening Customs Enforcement, issued on June 3, 2026.

While the executive order addresses a broad range of customs compliance issues, including importer-of-record requirements, customs fraud, undervaluation, and trade enforcement, it specifically directs the secretary of homeland security and the attorney general to prioritize enforcement relating to imports involving products produced with forced labor.

The order places forced labor enforcement alongside other identified customs enforcement priorities, including misclassification, undervaluation, illegal transshipment, and investigations conducted under the Enforce and Protect Act.

The inclusion of forced labor among the administration’s stated customs enforcement priorities is significant because it elevates the issue beyond CBP-specific activity and signals broader federal attention to forced labor compliance within trade enforcement efforts.

USTR PROPOSES SECTION 301 REMEDIES TARGETING FORCED LABOR TRADE PRACTICES

On June 2, 2026, USTR announced determinations in 60 separate Section 301 investigations relating to foreign governments’ failures to impose and effectively enforce prohibitions on the importation of goods produced with forced labor.

USTR determined that the acts, policies, and practices of all 60 investigated economies are unreasonable and burden or restrict US commerce. According to USTR, these failures undermine efforts to eliminate forced labor, distort market conditions, disadvantage companies that do not use forced labor, and contribute to the circumvention of existing forced labor import restrictions.

USTR found that 54 economies failed to impose and effectively enforce a forced labor import prohibition, while six economies were found to have failed to effectively enforce existing prohibitions. As a result of these findings, USTR has proposed additional Section 301 duties on imports from the investigated economies. Proposed tariff rates generally range from 10% to 12.5%, subject to certain exceptions and a proposed textile mechanism that would permit qualifying apparel and textile imports from certain economies to enter at reduced tariff rates.

The investigations are notable not only because of their scope but also because they represent an effort to address forced labor through broader trade policy tools in addition to traditional customs enforcement mechanisms.

WHAT THESE DEVELOPMENTS MEAN FOR INTERNATIONAL TRADE

Viewed collectively, these developments suggest that the government is increasingly treating forced labor as a broader trade policy issue rather than solely a customs enforcement matter.

The new WROs demonstrate continued willingness by CBP to pursue forced labor investigations outside the context of Xinjiang and the UFLPA. The executive order elevates forced labor within the administration’s customs enforcement priorities. USTR’s Section 301 findings expand the issue into the trade policy arena and create the potential for additional tariff measures tied to forced labor concerns.

The developments also reflect growing expectations regarding supply chain transparency and traceability. CBP’s new guidance effectively provides a roadmap for the documentation and due diligence measures importers may need to demonstrate compliance if their shipments are detained or challenged.

For businesses engaged in international trade, the message is clear: forced labor compliance remains a significant enforcement concern and may become a more prominent focus of both customs and trade policy initiatives going forward.

WHAT COMPANIES SHOULD DO NOW

Companies with international operations and complex supply chains should consider taking several proactive steps.

• Reassess forced labor risk across the supply chain: Companies should evaluate exposure not only in traditionally high-risk regions and sectors but also among suppliers and jurisdictions that may not have historically been associated with UFLPA-related scrutiny.
• Evaluate supply chain visibility and traceability capabilities: Businesses should assess whether they can identify and document the origin of materials, components, and finished goods throughout their supply chains.
• Review supplier oversight and due diligence processes: Importers should examine supplier agreements, audit rights, compliance certifications, and due diligence procedures to ensure they can obtain the documentation necessary to respond to CBP inquiries and enforcement actions.
• Assess documentation and recordkeeping practices against CBP expectations: Businesses should determine whether their record retention, tracing, and compliance documentation align with the standards outlined in CBP’s new operational guidance, particularly for products sourced from higher-risk jurisdictions or sectors.
• Prepare for potential detentions and exclusions: Companies should review internal response protocols and ensure that legal, trade compliance, procurement, and supply chain teams understand their respective roles if CBP detains or excludes merchandise.
• Monitor evolving trade measures tied to forced labor concerns: Importers should track the USTR Section 301 proceedings and any resulting tariff actions that could affect sourcing strategies, landed costs, supplier relationships, or broader supply chain planning.

Conclusion

Recent actions by CBP, USTR, and White House suggest that forced labor enforcement is assuming a more prominent role within the administration’s broader trade and customs agenda. Although the ultimate scope and pace of enforcement remain uncertain, the combination of new WROs, expanded importer guidance, express enforcement priorities, and proposed Section 301 actions points toward increased scrutiny of supply chains and import compliance. Companies with global operations should use this period to evaluate their forced labor compliance frameworks, strengthen supply chain visibility, and prepare for a potentially more active enforcement environment.