US Forced Labor Ban: New Targets, More Detentions, and What You Need to Know

On August 19th, the U.S. Department of Homeland Security published its annual update on its strategy to enforce the U.S. ban on goods made whole or in part with forced labor. The ban requires such updates to be submitted to Congress each year. 

While the Forced Labor Enforcement Task Force (FLETF) has not added new entities to its Entity List since January of this year, the strategy highlights FLETF’s intent to target new high-priority sectors including lithium, steel, copper, red dates (aka jujubes) and caustic soda. These new sectors will likely result in additions to the official Entity List as well as an increase in detentions and seizures for companies utilizing these materials. 

Over the last few months the U.S. has significantly increased the volume of shipments detained upon entry, due in part to an increase in detentions in lower value goods such as consumer electronics (compared to high value goods such as automobiles and solar panels, which continue to face detentions as well). While the value of goods detained to date is far less than the value detained during the equivalent time period in 2024, the number of shipments detained to date (6,636) has already exceeded 2024 in its entirety (4,598).

The annual DHS update also included some highlights regarding FLETF’s efforts around global collaboration, most notably an agreement between DOL, Treasury and multilateral development banks to require traceability to metallurgical grade silicon for solar products under consideration, and to exclude the sourcing of products from companies on the Entity List. 

Supply chain transparency and traceability continue to be a top priority for companies looking to import into the United States. The steady increase in detained shipments coupled with the addition of new high-priority sectors point to DHS and FLETF’s continued commitment to enforcing the U.S. forced labor ban, as well as the importance that companies proactively prepare. 

To learn more about how Sourcemap can help your business comply with the strictest forced labor due diligence requirements, reach out to our team of experts.