As governments tighten restrictions on goods linked to forced labour in China’s Xinjiang region and elsewhere, the issue has become an increasingly prominent point of tension in international trade and diplomacy.
The United States has stepped up enforcement of the Uyghur Forced Labor Prevention Act, while in Australia, allegations of forced labour in supply chains have prompted legal action against major retailers.
Yet despite tougher laws and growing scrutiny, significant loopholes remain and for the workers subjected to coercion, their voices are often the hardest to hear.
U.S. steps up enforcement, but supply chain loopholes remain
In mid-August, the US Department of Homeland Security added Chinese steel, copper, lithium, caustic soda and red dates to a list of products subject to heightened scrutiny under the Uyghur Forced Labor Prevention Act (UFLPA).
The move brought the number of high-priority sectors and products identified by US authorities to 12, including aluminium, cotton and cotton products, PVC, tomatoes and tomato products, seafood and polysilicon. The additions reflect what US authorities say are growing concerns about links between these industries and the risk of forced labour in Xinjiang.
Since the UFLPA came into force in June 2022, US Customs and Border Protection had, by early August this year, detained more than 16,700 shipments worth about $3.7bn for inspection. More than 10,000 shipments, with a total value of nearly $900m, were ultimately denied entry to the United States over suspected links to forced labour.
The US has also placed 144 Chinese companies on a blacklist, effectively barring their products from entering the American market.
The figures point to an increasingly aggressive enforcement regime. But they also expose the limits of a system struggling to keep pace with the complexity of global supply chains.
The UFLPA can restrict goods entering the US directly from China, but companies can still exploit opaque supply chains and third-country transshipment routes to obscure where products — or their components — originate. Materials linked to Xinjiang may pass through several countries and factories before reaching western consumers, making them increasingly difficult to trace.
And forced labour is not confined to Xinjiang.
A narrow focus on the region risks creating another blind spot: labour abuses and sweatshop conditions elsewhere in China may receive far less scrutiny, even as international companies continue to source from the country.
Australian lawsuit exposes weaknesses in Modern Slavery Act
Australia is facing its own debate over forced labour and corporate responsibility. In August 2025, the Australian Uyghur Tangritagh Women’s Association (AUTWA) filed proceedings in the Federal Court seeking access to supply chain documents from retail giant Kmart. The organisation hopes to determine whether products sold by the company are linked to forced labour in Xinjiang.
The legal action highlights allegations that a Jiangsu factory listed among Kmart’s suppliers had previously been questioned by United Nations experts as raising concerns over possible forced labour. Although Kmart says it operates under ethical sourcing standards, the group argues the company has not provided sufficient transparency to reassure consumers that its supply chain is free from labour exploitation. The legal action has also exposed weaknesses in Australia’s Modern Slavery Act.
Introduced in 2018, the legislation requires companies to publish annual statements outlining the risks of modern slavery within their supply chains. However, it does not require action and carries no penalties for non- compliance. The system relies heavily on corporate self-reporting, while government oversight remains limited, leaving civil society groups to turn to the courts to force greater transparency.
In 2023, the Australian government commissioned former Commonwealth ombudsman John McMillan to review the legislation. His recommendations included introducing financial penalties and publishing a list of high-risk entities. But formal consultation did not begin until the end of 2024, and no substantive amendments have yet been enacted.
Experts warn that without stronger enforcement, Australia risks becoming a “safe haven” for products linked to forced labour, with goods refused entry to the United States potentially being redirected to the Australian market.
Delayed EU ban will test enforcement and political will
A global network of measures aimed at keeping goods made with forced labour out of markets is gradually taking shape, but significant weaknesses remain.
At the end of 2024, the European Union adopted the Forced Labour Regulation, prohibiting products made using forced labour from being sold within or exported from the EU. Unlike the U.S. legislation, which focuses largely on goods connected to Xinjiang, the EU regulation applies globally, making it one of the broadest legal frameworks introduced to tackle forced labour in international trade.
However, the legislation will not take effect until December 2027, leaving a three-year transition period. In the meantime, products linked to forced labour may continue entering the European market.
The EU’s enforcement model also relies on investigations into individual cases rather than the kind of presumption-based import ban used by the US. That could leave scope for suspect goods to remain in circulation while inquiries are under way.
Ending modern slavery demands collective action
The contrasting approaches adopted by the U.S., Australia and the EU demonstrate a common recognition of the seriousness of forced labour, but also stark significant differences in how governments choose to respond.
The U.S. has demonstrated that aggressive enforcement can have an impact, while struggling to prevent goods from being rerouted through third countries. Australia has a legal framework that has been criticised for relying too heavily on corporate disclosure without meaningful enforcement. The EU has introduced one of the world’s most comprehensive legal frameworks, but its delayed implementation and case-by-case enforcement leave questions over how effective it will work in practice.
These experiences underline a broader lesson: tackling forced labour requires far more than passing new legislation. It also requests governments to accept the political and economic costs of enforcing them.
Without meaningful international coordination and implementation, even the toughest legislation risks becoming little more than words on paper
To bring modern slavery to an end, governments must move forward simultaneously on legislation, enforcement and international cooperation.They need robust and transparent regulatory systems , effective cross-border information sharing and clear mechanisms for holding companies and other actors to account .
Only through coordinated international action can the space for forced labour within global supply chains finally be dismantled.