Coalition to End Forced Labour in the Uyghur Region

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Import Ban Legislation Resources

State-imposed forced labour is distinct from forced labour carried out by private actors. State-imposed forced labour refers to forced labour imposed by state authorities, agents acting on behalf of state authorities, and organisations with authority similar to the state. It is contrary to the state duty to to protect its population under core human rights treaties and ILO Conventions. State-imposed forced labour is embedded in government policy and enforced through the state and requires a different response by companies. A mix of regulatory tools, including forced labour import bans, mandatory human rights due diligence, and transparency laws, is needed to address the widespread, state-imposed forced labour facing the Uyghur people.

Import bans on goods made with forced labour have the potential to be an effective tool for addressing corporate complicity in state-imposed forced labour. They should include an explicit provision to ban products from an entire region or supply chain tainted by forced labour, such as products from the Uyghur Region. Further, the burden of proof should be shifted to the importer for any products from regions or supply chains identified as using state-imposed forced labour.

As explained below, some legal measures are driving companies to trace their supply chains down to the raw materials, shifting sourcing away from the Uyghur Region, and imposing consequences on companies for non-compliance. 

However, many of the import bans, as well as transparency and due diligence frameworks, that have been implemented in various countries, fall short in their scope and enforcement, leaving global supply chains deeply exposed to state-imposed forced labour. As state-imposed forced labour transfers are expanding – more than 3 million forced labour transfers were reported in 2023 – hundreds of corporations continue to fail to address these risks. 

A coordinated global response is essential to ensure there is no market anywhere for goods made with Uyghur forced labour. Below are resources outlining effective policy approaches to address Uyghur forced labour in global supply chains. 

Coalition Resources

Section 307 of the Tariff Act of 1930 prohibits the importation of goods made wholly or in part with forced labour and provides the legal basis for enforcement tools, including Withhold Release Orders (WROs) and Findings. 

In June 2022, the Uyghur Forced Labor Prevention Act (UFLPA) entered into force, strengthening this framework by establishing a rebuttable presumption that any goods mined, produced, or manufactured-wholly or in part-in the Uyghur Region, or by entities implicated in forced labour, are prohibited from entering the United States. To date, no importer has met the evidentiary standard required to rebut this presumption. 

Since its implementation, UFLPA enforcement has targeted billions of dollars in high-risk imports, preventing tens of thousands of shipments suspected of being produced with forced labour from entering the U.S. market and driving necessary shifts in global supply chains. The UFLPA Entity List includes nearly 150 entities identified as participating in the state-sponsored labour transfer schemes in the Uyghur Region and/or sourcing from these entities. However, new data shows a more than fourfold decline in UFLPA enforcement between April and August 2025 and no new additions to the UFLPA Entity List since January 2025. 

More generally, at the federal level, the U.S. has limited transparency requirements related to forced labour, including import disclosure obligations, and does not mandate human rights due diligence across supply chains.

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Canada’s Customs Tariff prohibits the importation of goods produced wholly or in part by forced labour, reflecting commitments under the Canada-United States-Mexico Agreement (CUSMA) to prohibit the importation of goods produced in whole or in part by forced labour. The prohibition came into force in July 2020 and applies to all imports regardless of origin. However, transparency and enforcement remain limited. Since 2021, the Canada Border Services Agency has detained roughly 50 shipments suspected of forced labour, only one of which was denied entry after review.  

Despite a stated commitment to address Uyghur forced labour, the current framework does not include legislation establishing a rebuttable presumption of forced labour for goods from high-risk regions or specific product groups. 

Canada’s Fighting Against Forced Labour and Child Labour in Supply Chain Act, which came into force in January 2024, requires annual reporting by certain companies, but does not mandate human rights due diligence. 

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In 2024, Mexico enacted the Decree Amending and Adding Various Provisions of the Customs Law in accordance with its obligations under the United States-Mexico-Canada Agreement (USMCA) to prohibit the importation of goods produced in whole or in part by forced labour. Amendments effective October 2025 expanded the Secretariat of Labor’s investigative powers and clarified procedures, but transparency and practical enforcement remain limited, with no public reports on actions or detained shipments. 

Mexico does not currently have mandatory human rights due diligence or supply transparency legislation addressing forced labour risks.  

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The UK does not have standalone import ban legislation prohibiting goods made with forced labour. The UK Modern Slavery Act 2015 requires companies to report on steps taken to address forced labour risks annually, but does not mandate human rights due diligence.  While an amendment to the Great British Energy Act 2025 is aimed at ensuring that slavery and human trafficking are not taking place in energy supply chains of the publicly-owned energy company, Great British Energy, a comparable provision is not yet in place for other industries.  

In June 2024, the Court of Appeal ruled that companies that knowingly or with reasonable suspicion import goods made under criminal circumstances, such as through Uyghur forced labour, can now be prosecuted under the Proceeds of Crime Act 2002 for trading criminal property.  

An amendment to the Health and Care Act 2022 bars the National Health Service (NHS) from using goods and services linked to slavery or human trafficking. NHS procurement regulations (effective May 2026) implement these exclusion powers.

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The EU Forced Labour Regulation, in force since December 2024 and fully applicable from December 2027, bans the import, placement on, or export from the EU market of products made with forced labour. However, it does not create a rebuttable presumption or automatic regional ban for cases of widespread state-imposed forced labour. Implementation and enforcement will be conducted by the European Commission and by competent authorities in each Member State, with Member States required to designate authorities by December 2025. The European Commission is also expected to establish a forced labour risk database by June 2026. Separately, the Corporate Sustainability Due Diligence Directive (CSDDD) and national laws of several Member States impose mandatory human rights due diligence obligations on companies.  

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Australia does not have standalone import ban legislation prohibiting goods made with forced labour. The Modern Slavery Act 2018 requires certain large businesses to disclose the steps they have taken to identify and address modern slavery risks in their global supply chains and operations, but does not mandate human rights due diligence. 

In August 2025, Anti-Slavery Commissioner Chris Evans called for urgent reforms to the Modern Slavery Act 2018, emphasizing the need for stronger enforcement tools, including high-risk product lists and import bans.

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Japan’s 2022 Guidelines on Respecting Human Rights in Responsible Supply Chains encourage companies to conduct human rights due diligence across their supply chains, but they are not legally binding. Lawmakers within the Japan Uyghur Parliamentary Association have announced plans to draft legislation modeled on the UFLPA. 

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Several European countries, including Austria, Belgium, France, Germany, the Netherlands, Norway, and Switzerland, have adopted or are developing mandatory human rights due diligence laws. Ongoing legal cases in Germany, the Netherlands, and France are targeting companies linked to state-imposed forced labour. Across Asia, mandatory human rights due diligence measures are emerging, including in South Korea, Thailand, and Indonesia.  

A number of jurisdictions have made commitments to adopt forced labour import prohibitions through Agreements on Reciprocal Trade with the United States, including Argentina, Bangladesh, Cambodia, Ecuador, Guatemala, Indonesia, Malaysia, Taiwan, and El Salvador. However, most of these commitments are yet to be translated into domestic law or effective enforcement systems.  

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