cross-posted from: https://mander.xyz/post/54165365
As the United States and European Union tighten restrictions on goods made with forced labor, mid-sized economies face a growing risk: high-risk imports may be redirected toward markets with weaker enforcement.
A new report examines the risk in Australia and Japan, two major economies deeply integrated into Chinese supply chains but lacking forced-labor import prohibitions.
Key points:
Forced-labor risk is being redistributed, not eliminated. As the United States enforces the Uyghur Forced Labor Prevention Act (UFLPA) and the European Union (EU) prepares to apply its Forced Labor Regulation, high-risk goods may flow toward markets without comparable import controls.
Mid-sized economies such as Australia and Japan remain exposed. In 2024, Australia imported roughly $4.82 billion in high-risk goods from China, while Japan imported roughly $6.71 billion.
Risk is concentrated in strategic sectors. Cotton apparel and textiles, solar inputs, aluminum, and chemical products remain key channels through which Uyghur forced-labor risk can enter consumer and industrial supply chains.
Transparency is not enforcement. Australia’s Modern Slavery Act and Japan’s human rights supply-chain guidelines promote disclosure and due diligence, but neither block high-risk goods at the border.
Mid-sized economies need enforceable tools. Australia and Japan should adopt forced-labor import prohibitions, importer traceability requirements, customs enforcement authority, and mandatory human rights due diligence.
Recommendations for Closing the Enforcement Gap according to the report:
- Adopt forced-labor import bans modeled on the UFLPA. Australia, Japan, and other mid-sized economies should adopt forced-labor import prohibitions that condition market access on credible supply-chain evidence …
- Pair import bans with traceability, customs authority, and mandatory due diligence. Import prohibitions will be effective only if governments give customs agencies the authority, resources, and data needed to enforce them. Australia and Japan should require importers to map supply chains, document upstream inputs, and provide credible evidence for high-risk goods. These rules should be paired with mandatory human rights due diligence so companies identify, prevent, and address forced-labor risks …
- Coordinate enforcement across major and mid-sized markets. Unilateral action can reduce exposure in one market while shifting high-risk goods to other markets. The United States, European Union, Australia, Japan, and other partners should align enforcement efforts through shared customs data, common risk indicators, public-entity lists, and coordinated approaches to high-risk sectors and regions …
- Formally include civil society and affected communities in enforcement. Civil society organizations often identify risks before governments act. The Kmart case shows how groups such as the Australian Uyghur Tangritagh Women’s Association can expose supply-chain concerns, but also how limited legal tools force communities to rely on indirect pathways for accountability. Governments should strengthen whistleblower protections, establish evidence-sharing mechanisms, and provide affected communities with clearer legal avenues to initiate investigations or challenge high-risk imports.
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