United States Legislation:
At the state level, California’s Transparency in Supply Chains Act requires large organisations to publicly disclose how they address risks related to forced labour and human trafficking within their direct supply chains. Although the legislation is primarily disclosure focused, it has still established baseline expectations. These relate to supplier governance, procurement oversight, and transparency. They apply to businesses operating in or selling into the California market.

Greater operational risk often arises at the federal level. Under the Tariff Act of 1930, U.S. Customs and Border Protection has the authority to detain shipments. This applies where there is reasonable suspicion that goods have been produced using forced or indentured labour. These actions, implemented through Withhold Release Orders, can immediately interrupt import activity and create significant commercial disruption.

Enforcement has strengthened further through the Uyghur Forced Labour Prevention Act. It introduces a rebuttable presumption that goods connected to the Xinjiang region are produced using forced labour. Importers must demonstrate otherwise to overcome this presumption. As a result, supply chain compliance increasingly depends on detailed traceability, credible supporting evidence, and defensible sourcing practices, shifting expectations well beyond disclosure alone.