Request for Comments: Trade Strategy to Address Forced Labor – International Trade and Investment


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On July 6, 2022, the Office of the United States Trade Representative (USTR) issued a Notice and Request for Comments (RFC) on the Biden administration’s “Trade Strategy to Combat Forced Labor.”1 The deadline for comments is
August 5, 2022.

The RFC follows USTR Katherine Tai’s January 25, 2022 announcement that the USTR would create its first-ever strategy to address forced labor in traded goods and services. To develop this strategy, the Trade, Forced Labor, and Child Labor Subcommittee of the USTR Trade Policy Staff Committee (TPSC) will examine the strengths and weaknesses of existing U.S. government interagency policies and tools regarding forced labor. The USTR invites interested parties, including the private sector and labor organizations, to submit comments that will be used to define the objectives, tools and actions of the strategy.

To guide commenters in their responses, the RFC invites parties to ask themselves the following questions:

  • What actions could the U.S. government take with like-minded business partners and allies to combat forced labor as an unfair trade practice?

  • How can the US government strengthen the forced labor components of trade agreements and trade preference programs to have greater effect?

  • What new and innovative trade tools can the U.S. government develop and use to advance efforts to combat forced labor in traded goods and services?

  • How can the US government make forced labor trade policy-making a more inclusive process?

  • Do you have any additional recommendations for monitoring, tracing or eliminating forced labor in goods and services traded in supply chains?

The USTR’s RFC also follows the release by the Biden administration’s Forced Labor Enforcement Task Force of a Uyghur Forced Labor Prevention (UFLPA) Law Enforcement Strategy, which entered into force in June 2022.

Stephanie Rigizadeh, Wiley 2022 Summer Associate, contributed to this alert.


1. Invitation to Comment: Business Strategy to Combat Forced Labor, 87 Fed. Reg. 40,332 (off. U.S. Trade Representative, July 6, 2022).

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