Breaking Unseen Chains: CBP Leading the Global Fight Against Forced Labor

U.S. Customs and Border Protection at the Port of New York/Newark inspected a shipment of hair pieces and accessories from China, part of which is suspected to have been made with forced or prison labor. Courtesy photo

 

A young woman leaves home with a bag containing a few essentials—enough for a couple of weeks. Perhaps she is a mother seeking to support her children. Perhaps she is a daughter wanting to provide for her aging parents. Struggling to make ends meet and seeking opportunities she can’t find at home, she signed a contract in a language she doesn’t understand, trusting the recruiter’s promises of steady work and a chance to provide for her loved ones. She needed the job. 

When she arrives at the factory, those promises begin to unravel. Her new boss confiscates her passport, preventing her from leaving or finding other work. Her supervisors start monitoring her around-the-clock. They dictate where, when, and how she works, ensuring a relentless pace of production.  

Heavy waves of industrial chemicals hit her lungs. She is strong, but not strong enough to bear the non-stop physical demands of the production line. Her days start before sunrise and stretch long into the night, with barely any time to rest.  

She may be one of the workers whose wages are withheld for many months. Or perhaps her wages are siphoned away through unexplained fees, like room and board. It’s not enough to send back home, but complaining isn’t an option. The consequences—whether intimidation, violence, or worse—were made clear. Trapped by the contract she signed and conditions she never agreed to or understood, whoever she is, she works silently and alone, with no way to escape. 

Her story reflects a brutal reality faced by millions of workers around the world who find themselves trapped in forced labor. From factories and fields to internment camps and sea vessels, forced labor exploits vulnerable or oppressed individuals hidden behind complex global supply chains, and thrives on isolation and fear.  

Addressing the scourge of forced labor requires a concerted effort from governments, businesses, civil society, and consumers to strengthen regulations, enhance transparency, and protect these vulnerable workers.  

And in the past decade, U.S. Customs and Border Protection (CBP) has been at the forefront of this battle. By enforcing laws that prevent the importation of foreign goods produced with forced labor, CBP addresses these practices where they begin—at the point of production—and has emerged as a global leader in this fight.  

“Our investigations and our enforcement are to stop companies from importing goods made at the expense of someone’s freedom,” said Trisha Tran, a Branch Chief assigned to CBP’s Forced Labor Division.  

“By preventing goods made with forced labor from entering the U.S., CBP uplifts vulnerable workers who have been silenced.” 

The Many Faces of Forced Labor 

According to the International Labour Organization, 28 million workers are trapped in forced labor worldwide—a population larger than Australia. These women, men, and even children, find themselves stuck in cycles of debt and coercion, unable to escape exploitative systems designed to profit from their suffering. 

Companies use forced labor to decrease costs and maximize profits, which ring in at $236 billion a year. Tragically, the vast majority of that money doesn’t make it back to the workers who are separated from their families, required to work overtime, and who may have been physically or even sexually abused as they toiled to increase production. In fact, those profits often fund transnational criminal organizations and other illegal activities like counterfeit goods manufacturing, drugs and arms trafficking, terrorism, and other violent crimes. 

Forced labor affects people of all backgrounds, including persecuted minorities, individuals with disabilities, children, and adults. Victims often face unsafe working and living conditions, food deprivation, and exploitation of their poverty and other vulnerabilities—each tactic designed to dehumanize and prevent escape. 

Forced labor takes many forms and can seep into global supply chains at numerous points.  

On remote fishing vessels, for example, workers may be lured with promises of decent wages but suddenly find that they owe significant “recruitment fees,” effectively beginning their job in debt. Their insufficient wages don’t cover these fees; they are trapped in this cruel, endless cycle of debt bondage which brings them back year after year. Sometimes, there’s no escape: workers are forbidden to leave the vessel, forced into extreme isolation, and restricted from contact with the outside world.   

In other examples, forced labor takes place on farms that grow everyday staples we rely on: tomatoes, cotton, sugar, beans, rice, and more. Workers may live in cramped, decrepit shelters that barely shield them from the heat or cold. They lack access to clean water, sufficient food, and medical care. Verbal abuse and physical threats are a common way to force workers to stay. 

As products made under these conditions move along the supply chain, they are transformed into countless consumer goods: shrimp and fish that appear on our dinner tables, cotton woven into our clothing, sugar in our confections, and ingredients that find their way into cosmetics.  

By the time they reach our shelves, it can be nearly impossible for the unwitting consumer to trace them back to the suffering of the people who made them possible.  

How CBP Protects American Businesses from Forced Labor 

The hard truth is that these goods often end up in American stores and online shopping carts heading for American homes.  

This not only affects consumers, but also American businesses committed to fair labor practices. Legitimate companies that pay fair wages, ensure safe working conditions, and follow ethical standards find themselves competing against imports produced under brutal, unlawful circumstances.  

CBP’s Forced Labor Division Director, Brian Hoxie, explains the impact goods made with forced labor have on U.S. industries. “When American businesses are forced to compete with unfairly low prices driven by exploitative labor, the entire system suffers. Nobody wins—not businesses, not workers, and not consumers,” said the director.  

“Our work is leveling the playing field and boosting domestic industries,” he continues. “CBP’s forced labor enforcement protects American businesses by ensuring they are not undercut by competitors who don’t play by the rules.”  

By preventing goods made with forced labor from gaining a foothold in the American marketplace, CBP’s enforcement measures send a powerful message that resonates far beyond our borders.  

Increasingly, industries worldwide are realigning their business models to comply with these principles. By holding companies accountable at every step of their supply chain—from raw materials to finished products—CBP’s actions are promoting transparency, responsible sourcing, and a commitment to human rights across global trade.   

Ultimately, CBP’s work strengthens the integrity of American markets, rewards ethical practices, and helps ensure that the goods we buy do not come at the expense of human freedom and dignity.  

A Turning Point in Forced Labor Enforcement 

Although the U.S. government’s focus on this issue may seem recent, our country has long prohibited goods made with forced labor—since 1930. Section 307 of the Tariff Act of 1930 prohibited imports produced entirely or in part using forced labor from entering the United States commerce.   

Unfortunately, a single clause in the legislation allowed goods made with forced labor to enter the U.S. market if the domestic supply chain could not meet national demand. This exception weakened enforcement for decades.  

However, in 2016 the Trade Facilitation and Trade Enforcement Act closed this loophole, marking a turning point in the fight against forced labor. Shortly after, in 2017, CBP established the Forced Labor Division, positioning the agency as the global leader in tackling forced labor.  

CBP is the only agency in the U.S. government charged with enforcing laws to keep products made with forced labor out of U.S. markets. Armed with this authority, CBP investigates and combats forced labor practices through powerful enforcement tools, including Withhold Release Orders (WROs) and Findings, which allow the agency to detain or seize goods before they enter the U.S. if there is reasonable suspicion or probable cause of forced labor.  

These tools have enabled CBP to take swift and decisive action, setting the global standard for enforcement. Since 2017, CBP has issued 37 WROs and 5 Findings, and is actively enforcing 51 WROs and 9 Findings. As a result of these forced labor enforcement actions, CBP has stopped approximately 3,400 shipments potentially marred by forced labor with a value of over $800 million.  

These actions target a wide range of industries, from agriculture and textiles to manufacturing and technology, sending a clear message to companies that forced labor will not be tolerated in any U.S. market.  

Landmark Changes: Uyghur Forced Labor Prevention Act 

In 2021, CBP’s efforts to combat forced labor reached a pivotal turning point with the passage of the Uyghur Forced Labor Prevention Act.  

This groundbreaking legislation targets goods made in China’s Xinjiang Uyghur Autonomous Region, where the Chinese government continues to execute a campaign of repression and genocide targeting the Uyghur people and other ethnic and religious minority groups with the systemic use of forced labor. The Uyghur Forced Labor Prevention Act establishes a rebuttable presumption that any goods made in this region are a result of forced labor, barring them from entry into the U.S.  

The Act, and CBP’s enforcement of it, has spurred a dramatic shift in how global industries approach supply chain compliance across commodities in all sectors, especially in textiles, apparel, solar, automotive, and Polyvinyl Chloride flooring.  

Many U.S. companies have responded by overhauling their sourcing practices to ensure their supply chains are free from the stain of forced labor. Industry reports indicate that more than 95% of U.S. apparel companies of U.S. apparel companies, for example, have actively enhanced their supply chain due diligence efforts with the use of technology and verification tools. 

To avoid goods linked with forced labor, companies have established or strengthened existing social compliance programs to mitigate risk and increased due diligence practices to investigate and assess their supply chains to ensure compliance with the UFLPA.  

CBP has stopped billions of dollars’ worth of goods suspected of forced labor from the Xinjiang Uyghur Autonomous Region. Since implementation, CBP stopped 10,633 shipments valued at $3.66 billion for UFLPA enforcement action reviews and denied 43% ($800 million) of shipments stopped. 

While UFLPA ultimately strengthened CBP’s enforcement posture against forced labor, it also expanded the division’s capacity, enabling tremendous growth in staffing and resources within just a few short years.  

“Our forced labor enforcement posture has strengthened tremendously in a few short years,” said Auco Ho, a Branch Chief in CBP’s Forced Labor Division. “We approach forced labor enforcement from all throughout our agency to meet the growing demands.” 

By combining this expanded capacity with its growing expertise in enforcing forced labor, CBP—drawing on a diverse team of auditors, trade specialists, investigators, and field personnel, as well as staff in its Centers of Excellence and Expertise—has significantly enhanced its ability to identify and address hidden abuses. Across the nation, the CBP team—reflecting a whole-of-agency commitment—work tirelessly to uncover these invisible supply chains.  

But Ho and CBP leadership have stressed that while the agency has dedicated significant resources to UFLPA enforcement, the organization continues its tireless investigation and pursuit of forced labor taking place anywhere in the world, not just in the Xinjiang Uyghur Autonomous Region. 

“Since the passage of the UFLPA, there has been a misconception outside of the agency that we are only looking at or investigating forced labor taking place in China. That is absolutely not true. Our focus on this issue has always been a global one,” said Executive Director Eric Choy of CBP’s Trade Remedy and Law Enforcement Directorate.  

Global Impact 

CBP’s leadership in forced labor enforcement is setting a global precedent: the U.S. remains the one of the few countries in the world currently imposing import bans on goods produced with forced labor.  

This leadership has spurred international momentum, influencing the European Union (EU) to adopt similar enforcement measures. The EU Council took a major step forward by adopting a regulation prohibiting products made with forced labor from entering the 27-member market. Once signed by the Presidents of the European Parliament, the regulation will come into effect three years after.  

The influence extends closer to home, as well. For the first time, the United States-Mexico-Canada Agreement (USMCA) now specifically obligates all parties to prohibit the importation of goods sourced from forced labor. Mexico now works to implement this obligation and align the policies with the U.S. approach to addressing forced labor. 

These advancements underscore how U.S. enforcement has catalyzed global action as the first country to set this standard of accountability in the fight against forced labor. 

CBP’s actions have also driven measurable change by directly influencing countries to reform their labor practices from within.  

Among these, Malaysia stands out. After CBP issued four WROs against Malaysian disposable glove manufacturers in 2020 and 2021, the Government of Malaysia started a series of labor reforms that are already delivering results, improving the conditions for countless workers.  

As a direct result of CBP's enforcement actions, Malaysia launched its first-ever National Action Plan on Forced Labour in November 2021 as a framework to eliminate forced labor in the country by 2030. In March 2022, Malaysia also renewed its commitment to combat forced labor by ratifying the International Labour Organization Protocol of 2014 to the Forced Labour Convention. As a result of this notable progress, the U.S. Department of State’s 2023 Trafficking in Persons report recently modified Malaysia’s ranking from Tier 3 to Tier 2 watchlist.  

This is an important example of how CBP’s efforts have sparked significant change across supply chains worldwide, setting a powerful example of accountability and generating waves of progress. 

Righting What’s Wrong 

For trapped workers like the young women and men who leave their homes with the hope of providing for their families, forced labor feels like an unbreakable cycle. CBP’s enforcement actions aim to break that cycle—not just by stopping goods tied to forced labor from entering the U.S., but by pushing companies to take responsibility and make meaningful changes.  

Through a process known as remediation, CBP gives companies the chance to demonstrate that they have addressed the forced labor in their supply chains. This process isn’t simple, nor is it optional. Remediation can include repaying workers the wages and recruitment fees that were unfairly taken from them, creating safer workplaces, or implementing stronger systems to prevent future abuse. Only when CBP is satisfied that these conditions have been met can their goods re-enter U.S. markets.  

CBP is as committed to facilitating the flow of legitimate trade as it is to prohibiting forced labor. To balance these priorities, the agency works collaboratively with companies to assist them in remediating forced labor conditions in their supply chains.  

Since 2017, CBP’s forced labor remediation efforts have improved living and working conditions for tens of thousands of workers including the repayment of more than $62 million in recruitment fees that had trapped workers in debt bondage.  

The impact is tangible.  

In one recent case, CBP issued a WRO against a multinational manufacturer after investigations revealed the presence of many International Labour Organization indicators of forced labor within its supply chain. 

To address the WRO, the company evaluated the forced labor indicators identified and then worked efficiently to remediate those conditions. They eliminated the fees that bonded workers to exploitative conditions and repaid wages that were diverted to paying those fees. They strengthened oversight of their recruiters and contractors. As a result, a worker’s union, which was previously barred, finally formed. This improved the process for reporting issues through channels such as third-party grievance reporting hotlines, which are crucial in addressing labor issues promptly and effectively.  

By strongly scrutinizing its operations and putting new practices into place, they assured CBP that the forced labor conditions at its facility would not be allowed to resurface.   

Once the firm demonstrated it addressed the forced labor violations in its operations, CBP suspended enforcement of the WRO, allowing entry of their products to the U.S. market to resume.  

The steps that this company took in addressing the forced labor violations in its operations are an example of taking meaningful actions that other businesses can now follow.  

What We Can Do 

While CBP has shone a spotlight on the horrific practice of forced labor, there is still much left to be done.  

Somewhere in a distant place, a man wakes up under the watchful eyes of guards. He spends his day assembling products he will never see on store shelves. He doesn’t choose when to rest, what to eat, how to dress, or when to leave. His story is just one of many.  

For millions of people, forced labor is a daily reality.  

CBP has emerged as a global leader in the fight to end this exploitation. By enforcing laws like the Uyghur Forced Labor Prevention Act and leveraging tools like Withhold Release Orders, CBP has driven real, systemic change in global supply chains. Goods tied to forced labor cannot enter U.S. markets without consequences, and tens of thousands of workers have seen their wages restored and conditions improved as a result.  

“Our mission is to improve lives,” said Forced Labor Division Branch Chief, Trisha Tran. 

Yet, the fight is far from over. Countless individuals remain trapped in abusive conditions, their stories untold. This challenge requires continuous, collective effort—from governments, industries, and consumers—to ensure a world where no one’s humanity is traded for profit.  

Will you join us? 

Consumers, you can help stop forced labor by researching the companies that make our products, supporting those with ethical labor practices, and avoiding goods known to be linked to forced labor exploitation. By choosing to not purchase products from retailers that import from supply chains compromised by forced labor, you can protect the rights and dignity of millions of vulnerable people.  

Companies can do their part against forced labor by understanding their supply chains, from raw materials to delivered finished products, and evaluating each step in the production process for forced labor risk. Companies should implement strict forced labor standards all along the supply chain and replace those suppliers that will not comply.  

CBP will continue leading the fight against forced labor, working alongside all those who share the commitment to safeguarding dignity, fairness, and freedom across global supply chains.  

Here’s how you can help: 

• If you have information on forced labor-tainted merchandise entering the United States and would like to submit an allegation, please submit information through our allegations webpage. 

• If you are an importer that wants to ensure that your supply chain is free of forced labor, CBP has due diligence resources to help you get started. 

• For more information about CBP’s efforts to combat forced labor, please visit our website.