States moving to restrict purchases tied to forced labor
Forced Labor Procurement Crackdown
As the 2026 federal enforcement deadline for prohibiting government procurement linked to forced labor rapidly approaches, states across the U.S. are intensifying efforts to eliminate forced labor from public contracts. This momentum is marked not only by accelerated timelines but also by expanded policy scopes and deeper engagement with historically neglected labor sectors. Complementing this state-level surge, federal import enforcement continues to sharpen its focus—most notably through high-profile seizures of forced labor-tainted solar panels—further raising the stakes for compliance and ethical sourcing across supply chains.
States Lead with Accelerated and Expanded Forced Labor Procurement Restrictions
Several states, including California, New York, and Washington, have moved beyond a simple race to meet the 2026 federal threshold. They are pioneering phased mandates and interim compliance requirements, compelling suppliers to act sooner and with greater transparency. Key developments include:
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Mandatory initial supply chain disclosures that require contractors to provide detailed information upfront on labor practices and potential forced labor risks.
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Targeted, risk-based supply chain audits, focusing on sectors and geographies with documented forced labor prevalence, now explicitly including domestic work (caregivers, cleaners) and agriculture—sectors historically marginalized in labor protections.
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Expanded labor definitions to ensure that protections cover vulnerable populations such as domestic workers, whose exploitation often occurs in isolated environments beyond traditional oversight mechanisms.
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Third-party verification mandates replacing voluntary self-reporting, introducing independent audits and certifications to enhance transparency and enforcement credibility.
This accelerated approach reflects a growing consensus that incremental, voluntary measures are insufficient to dismantle entrenched forced labor. Yet the patchwork nature of state timelines, standards, and enforcement protocols presents compliance challenges for businesses operating across multiple jurisdictions.
Federal Import Enforcement Intensifies, Highlighting Solar Panel Supply Chains
Federal agencies have amplified import controls, reinforcing state procurement reforms and signaling zero tolerance for forced labor-linked goods:
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Solar panels have emerged as the dominant category subject to U.S. Customs and Border Protection (CBP) seizures connected to forced labor, particularly those sourced from Chinese regions with documented abuses.
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This focus underscores a complex tension: while the U.S. pushes for expanded clean energy infrastructure, it must also ensure that these climate goals do not come at the cost of human rights violations.
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The layering of state procurement restrictions with federal import bans creates a demanding compliance environment, increasing commercial and reputational risks for companies sourcing from implicated regions.
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Heightened federal vigilance reinforces the imperative for rigorous due diligence, transparency, and accountability across supply chains, especially in high-value, high-risk sectors.
Spotlight on Vulnerable Sectors: Agriculture, Textiles, and Domestic Work
Recent developments intensify scrutiny on sectors long associated with forced labor risks:
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In agriculture, a recent federal indictment of a North Carolina-based farm labor contractor accused of forced labor spotlights persistent domestic vulnerabilities. The case illustrates how labor shortages and stalled immigration reforms exacerbate risks, pushing some employers toward exploitative practices.
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The TN visa program—a NAFTA-derived visa allowing qualified Canadian and Mexican professionals to work legally in the U.S.—has been highlighted as an underutilized tool that could mitigate labor shortages and reduce exploitation risks in sectors like agriculture and caregiving.
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The textile and apparel sector continues to draw attention due to ongoing abuses in major sourcing countries such as Bangladesh. State procurement policies aim to influence corporate sourcing decisions, pushing for reforms that may ripple through global trade networks.
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Perhaps most significant is the explicit inclusion of domestic workers—caregivers, cleaners, and other in-home laborers—in procurement restrictions. This inclusion represents a historic policy shift, recognizing the systemic exploitation faced by domestic workers operating largely outside traditional labor protections.
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Advocates connect this change to the broader labor justice movement, invoking leaders like Dorothy Bolden, who fought tirelessly for domestic worker rights.
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As one advocate emphasized:
“Effective procurement policies must encompass all vulnerable labor sectors, including domestic workers, to truly eliminate forced labor from public contracts.”
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The emerging discourse around Black labor rights further underscores the importance of valuing and protecting marginalized workers. Articles such as “Black labor matters, so don’t undervalue or play us cheap” highlight how undervaluation and systemic neglect of Black workers—many engaged in contract and domestic labor—perpetuate exploitation.
Business Impacts: Heightened Risks, Costs, and Calls for Harmonization
The evolving regulatory landscape is reshaping business operations and market dynamics:
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Contract eligibility risks have surged. Companies unable to verify forced labor-free supply chains risk exclusion from lucrative state and federal contracts.
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Due diligence obligations have expanded drastically, requiring sophisticated risk assessments, ongoing monitoring, and remediation measures that encompass complex global supply chains, including domestic and agricultural labor tiers.
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Compliance costs are rising, driven by investments in data management, supplier engagement platforms, independent audits, and workforce training.
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These reforms are catalyzing a market-wide ethical shift, with public procurement standards influencing private sector sourcing practices toward greater transparency and accountability.
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Stakeholders across sectors increasingly advocate for interstate harmonization of standards and information-sharing mechanisms to reduce duplication, simplify compliance, and foster predictable enforcement.
Voices from the Frontlines: Progress, Challenges, and Opportunities
Government officials, advocates, and industry leaders collectively acknowledge the transformative impact of these reforms:
“By leveraging the purchasing power of states, we can send an unequivocal message that forced labor is unacceptable in any part of our economy,” said a coalition spokesperson representing state procurement directors. “Our aim is to make ethical sourcing the norm, not the exception.”
Domestic worker advocates stress the critical need for inclusion and recognition:
“Recognition and protection of domestic laborers is long overdue. Procurement policies must reflect the realities of all vulnerable workers to be truly effective.”
Industry leaders recognize compliance challenges but also identify strategic opportunities:
“Though compliance requirements are increasing, these reforms push companies to innovate, building more transparent and resilient supply chains. Early adopters will likely gain a competitive edge,” said a supply chain executive in the electronics sector.
Voices from labor justice movements, including Black labor advocates, emphasize the intersection of race, labor, and human rights:
“Black labor matters—undervaluing or exploiting these workers perpetuates systemic injustice. Procurement policies must uphold dignity and equity for all workers, especially those historically marginalized,” stated a representative from SEIU.
Strategic Recommendations as 2026 Nears
For Businesses:
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Implement or enhance comprehensive forced labor due diligence frameworks covering all supply chain tiers, including domestic and agricultural labor.
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Obtain recognized third-party certifications and conduct independent audits to verify compliance.
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Engage proactively with suppliers and contractors to identify and mitigate forced labor risks.
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Invest in training, data systems, and compliance infrastructure aligned with evolving regulations.
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Explore immigration solutions like the TN visa to address labor shortages and reduce exploitation risks.
For Governments:
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Provide clear, accessible procurement guidelines with ongoing training for procurement officers.
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Establish rigorous vetting and continuous monitoring systems to enforce compliance effectively.
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Promote interstate collaboration to harmonize standards, share best practices, and ease compliance burdens.
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Ensure procurement policies explicitly protect domestic workers and other vulnerable labor groups, reflecting historical and contemporary labor justice imperatives.
Conclusion
The intensifying crackdown on government procurement linked to forced labor—bolstered by federal import seizures such as those targeting forced labor-tainted solar panels—signals a pivotal transformation in public procurement and human rights enforcement. By embedding stringent transparency mandates, rigorous verification processes, and expanded sectoral coverage, including domestic work and agriculture, states are setting a new ethical benchmark for supply chain accountability.
This evolving policy landscape reflects a nuanced understanding of forced labor’s persistence and structural drivers, aiming not only to eradicate exploitative practices but also to catalyze systemic change toward a more just and equitable economy. As the 2026 enforcement horizon approaches, coordinated, decisive action from governments, businesses, and advocates is essential to ensure forced labor has no place in the supply chains powering public projects and private enterprise.
This ongoing effort underscores the critical intersection of human rights, labor justice, and procurement integrity—reminding all stakeholders that ethical sourcing is not merely regulatory compliance, but a shared commitment to dignity, equity, and respect for all workers.