January 26, 2022

USTR Announces Development of a Trade Strategy to Combat Forced Labor

Holland & Knight Alert
Andrew K. McAllister | Francisco J. Sanchez | Mackenzie A. Zales


  • The U.S. Trade Representative announced the development of a trade strategy to combat forced labor at a meeting of the Interagency Task Force to Monitor and Combat Human Trafficking.
  • It is expected that efforts will continue across the U.S. government to develop and implement tools and strategies to prevent the use of forced labor globally.

Earlier this week, a Holland & Knight alert discussed the recently passed Uyghur Forced Labor Prevention Act and U.S. Customs and Border Protection's (CBP) request for public comments on how best to ensure that goods made with forced labor are not imported into the United States. As anticipated in that alert, U.S. government scrutiny of forced labor continues to increase. Of note, the U.S. Trade Representative (USTR) announced on Jan. 25, 2022, that it will develop its first focused trade strategy to combat forced labor. Ambassador Katherine Tai announced the new plan at the first meeting of the President's Interagency Task Force to Monitor and Combat Human Trafficking convened by President Joe Biden.

The USTR strategy will include:

  • a thorough review of existing trade policies and tools intended to combat forced labor
  • an identification of gaps and weak points in U.S. trade policy vis-à-vis forced labor, including forced child labor
  • the creation of an inclusive process that maximizes input from stakeholders such as labor organizations, civil society, survivors and the private sector
  • the establishment of objectives, priorities, new tools and key action items to combat forced labor

In the coming months, expect USTR to prioritize forced labor in discussions with trading partners, as well as additional efforts to highlight the issue globally as the U.S. government intensifies its increasingly "whole of government" approach to combatting forced labor.

Reach out to the authors of this alert or another member of Holland & Knight's International Trade Group if you need assistance understanding how this strategy may affect your business, conducting supply chain due diligence or addressing other trade concerns.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.

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