How Importers Can Identify and Prevent Forced Labor

Date of Publication: May 24, 2021

When individuals are made to provide labor or services through the use of fraud, force, or other types of coercion, this is called forced labor. Forced labor is a major issue that endangers the lives of forced laborers, negatively impacts consumers, and creates a lack of transparency in the global supply chain. As a result, United States law prohibits the importation of any goods that are mined, produced, or manufactured, either wholly or in part, through forced labor. Importers also have an important role to play in the fight against forced labor, and can work to prevent forced labor by being aware and prepared.

The 11 Indicators of Forced Labor

To help importers stay aware of the warning signs of forced labor, the International Labor Office (ILO) created a list of 11 key indicators of forced labor. The list serves to help individuals at every stage of the forced labor prevention process, from law enforcement officers to importers, spot the signs of forced labor.

The ILO’s 11 Indicators of Forced Labor are:

  1. Abuse of vulnerability
  2. Deception
  3. Restriction of movement
  4. Isolation
  5. Physical and sexual violence
  6. Intimidation and threats
  7. Retention of identity documents
  8. Withholding of wages
  9. Debt bondage
  10. Abusive working and living conditions
  11. Excessive overtime

If any the above issues occur in a place where imported goods are manufactured, it could be a sign that forced labor is being used to produce those goods.

List of Goods Produced by Child or Forced Labor

The Bureau of International Labor Affairs (ILAB) also maintains a list of goods which they have reason to believe are produced through either forced labor or child labor, in violation of international standards. ILAB’s list also includes the source countries for each good.

For example, the list shows that bananas imported from Belize could be the result of child labor, while artificial flower products from the Dominican Republic have a high risk of being produced through forced labor.

The extensive list can be viewed here.

Using SVAP to Identify Risk

One way that importers can ensure they avoid goods manufactured through forced labor is through the Supplemental Validation Audit Process, or SVAP. SVAP is an assessment program that identifies the risk of forced labor at

  • Employment sites, like factories
  • Labor providers, such as a recruitment agency

By focusing entirely on forced labor, SVAP

  • Provides a process for importers to detect and mitigate forced labor conditions in their supply chain
  • Demonstrates due diligence through a credible and proven program to regulators, customers, investors, and other stakeholders
  • Accommodates multiple levels of international supply chains

The SVAP process includes four main steps for identifying and preventing the importation of goods made through forced labor:

  1. Self-assessment questionnaire
  2. On-site audit
  3. Corrective action plan
  4.  On-site closure audit

Importers and companies that are interested in SVAP can learn more about the process here.

This content is intended for informational purposes. Due to the generality of this content, the provided information may not be applicable in all situations. We encourage the reader to review the most up-date-regulations directly with the U.S. government’s sources on forced labor, which can be found here.

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