ICAR comment to U.S. Trade Representative Highlights forced labor and Opaque Supply Chains as Significant Foreign Trade Barriers

On October 30th, ICAR, Humanity United Action, and the Human Trafficking Legal Center (HTLC) submitted a comment to the U.S. Trade Representative in response to the request for comments on significant foreign trade barriers for the 2026 National Trade Estimate Report.

In the comment we argue that labor rights abuses around the world are significant barriers for U.S. trade. Companies that rely on forced labor and other labor rights abuses cut costs on labor to artificially lower prices. This poses a direct threat to fair competition for U.S. businesses in the global marketplace.

Although the U.S. has strong laws in place to combat forced labor in U.S. imports, such as Section 307 of the Tariff Act of 1930 and the Uyghur Forced Labor Prevention Act (UFLPA), the U.S. remains the largest importer of goods at risk of being produced using forced labor annually. Enforcement officials rely on third party complaints regarding individual importers. However, to address a systemic issue such as forced labor in U.S. imports, enforcement bodies must take a systematic approach.

In our comment, we argue that forced labor can only be eradicated from U.S. imports if importers are required to provide comprehensive supply chain data upon import. There is precedent for supply chain data disclosure requirements associated with certain industries, such as Seafood, and we believe these should be expanded and used as a model for all imports.

To learn more, you can read the full comment here.