THE SUPPLY CHAIN DIVERSIFICATION FORCED LABOUR PARADOX
American companies spent the better part of the last decade diversifying their supply chains away from China to manage geopolitical and tariff risks. The unintended consequence? They have created new and more complex forced labour compliance exposures and US enforcement data and recent trade agreements show regulators are now targeting those new supply chains more aggressively.
From the margin to mainstream: forced labour’s rise in trade policy
Section 307 of the Tariff Act of 1930 prohibited forced labour imports for nearly 90 years, but it was rarely enforced. That changed dramatically in the 2020s.
In January 2025, the Biden administration issued the first ever comprehensive trade strategy to combat forced labour which outlined how the US was using trade policy to enforce labour standards and encouraging other countries to do the same.
Central to this strategy was the enforcement of the Uyghur Forced Labor Prevention Act (UFLPA). The UFLPA strengthens the US prohibition on importing goods made with forced labour in China, specifically targeting the Xinjiang Uyghur Autonomous Region (XUAR). It establishes a “rebuttable presumption” that goods linked to Xinjiang or listed entities are produced with forced labour, barring them from entry unless proven otherwise.
The presumption is not limited to goods produced by companies located in Xinjiang. It also applies to products made by companies outside of XUAR and outside of China that source material or produce even a portion of the product inside XUAR.
Apr-Jun 2026 Issue
Walgreens Boots Alliance