SHU Publishes "Desk-Based" Forced Labor Research Strategies

Jun. 23, 2023
By: Hannah B. Kreinik

Sheffield Hallam University (“SHU”) recently published its latest brief as part of its series on forced labor entitled, Know Your Supply Chains: Desk-Based Research Strategies to Identify Uyghur Region Exposure. Professor Laura Murphy, who coincidently gave a keynote address at the CBP Forced Labor Technical Expo in March, has spearheaded the brief series. This is part of the ongoing global enforcement of bans of imports made with forced labor.

SHU’s brief is focused on a few approaches to analyze supply chains for forced labor violations. The first is a recommendation to understand the company’s suppliers, their native languages, customs, as well as their ties to any parent firms or subsidiaries. This method should also include sub-supplier identification and Uyghur Region risk from second and even third-tier suppliers. SHU also emphasizes the importance of record-keeping to have easy access to supply chain information. Recording information on company supply chains may be helpful to determine the companies to avoid as suppliers, but also as evidence in countering a rebuttal presumption from CBP under 19 U.S.C. ⸹ 1307.

The brief emphasizes using all resources available to companies to trace their supply chains. Some sources recommended in the brief included supplier webpages and CBP reports. SHU also reiterates that suppliers directly free of forced labor may still have their own suppliers using material tainted with forced labor use, or presumptions of use. Companies must ensure a complete breakdown of supply chain tiers all the way to where the raw materials are produced. Research is the first step in response to forced labor free supply chains, even if it is an uphill-battle.  

Every supply chain is different and may require the use of different research methods to analyze forced labor based on the individual company’s supply chains. BRC can assist you in applying appropriate methods to mitigate your risk of non-compliance with forced labor regulations. In the times of exponential forced labor enforcement, it is better to be safe than sorry. The attorneys at BRC would be glad to help with any forced labor concerns or supply chain assessments.