On July 25, the UK Parliament’s Joint Committee on Human Rights issued its report Forced Labour in UK Supply Chains. This 99 page report explores forced labor in UK supply chains and makes recommendations for addressing the issues identified by the Committee. Among other things, the Committee is recommending changes to current UK corporate modern slavery compliance requirements, as well as mandatory human rights due diligence and a forced labor import ban. These and other recommendations are discussed in this post. The UK Government has two months to respond to the report.
The Joint Committee on Human Rights consists of 12 members, appointed from both the House of Commons and House of Lords to examine matters relating to human rights within the UK. The predecessor Committee published a report addressing forced labor connected to the UK in 2017, available here. The current report builds on that work, noting the lack of progress made in the UK since the 2017 report.
The Committee concluded that the existing statutory framework is not meeting the Government’s ambition that companies operating in the UK not have forced labor in their supply chain. The 2025 report notes that the UK imports a significant volume of goods from five sectors with high levels of forced labor: electronics, garments, fish, timber and textiles. The Committee further concluded that new legislation is needed, including mandatory due diligence, an import ban on goods linked to forced labor and civil liability for companies that do not take adequate steps to prevent forced labor in their supply chains. The Committee calls for the introduction of new legislation within one year of the publication of its report, i.e., by July 2026.
Modern Slavery Reporting
The Committee concluded that current UK Modern Slavery Act reporting requirements are not effectively motivating companies to address forced labor in their supply chains.
Recommendations
- The Government should strengthen the reporting duty under the Act by establishing effective accountability mechanisms for non-compliance.
- The Government should remove Section 54(4)(b) of the Act, which enables companies to comply by reporting that no action has been taken to address modern slavery.
As some readers will remember, there have been prior initiatives to strengthen the UK Modern Slavery Act. In September 2020, the then-UK Government announced a package of new measures to strengthen the transparency provisions of the Act, as discussed in this Ropes & Gray post. In 2021, a Modern Slavery (Amendment) Bill was tabled in the House of Lords that proposed additional disclosure and substantive compliance requirements and penalties for non-compliance (see this Ropes & Gray post).
Mandatory Human Rights Due Diligence
The Committee concluded that the UK’s current voluntary due diligence approach is not effectively addressing forced labor in supply chains.
Recommendations
- The Government should introduce mandatory human rights due diligence requirements throughout supply chains for businesses trading in the UK. In developing this legislation, the Government should consult with businesses and ensure that there is sufficient lead time for any new requirements to be implemented.
- In developing its own mandatory human rights due diligence legislation, the UK should be mindful of the outcome of the EU’s Corporate Sustainability Due Diligence Directive (which is still in play, as discussed here and here), in order to ensure that businesses which operate in both the UK and EU are not placed under conflicting regulatory burdens.
- Small and medium-sized enterprises should be subject to scaled requirements that are proportional and risk-based to manage the specific risks of forced labor in their supply chains.
- Regulatory oversight and accountability measures are needed to ensure compliance with these new due diligence requirements, including penalties for non-compliance that are proportional to company turnover.
Supply Chain Centre
The Government recently announced in the UK’s Trade Strategy that a Supply Chain Centre will be established within the Department of Business and Trade that may, among other things, improve businesses’ access to information.
Recommendation
- The Supply Chain Centre should support effective human rights due diligence by companies by providing a single point of access to verified information, guidance and resources.
Forced Labor Import Ban
The Committee noted as a comparison that both the US and EU have import bans on goods linked to forced labor. US legislation has been in place for roughly a century, with significant enhancements and most enforcement occurring in the last decade. For recent US enforcements statistics, see here and here. The EU adopted its Regulation in late 2024 (see this Ropes & Gray post). That Regulation currently is scheduled to take effect in December 2027, although it may be “simplified” as part of the expanding EU omnibus process.
Recommendations
- The Government should introduce an import ban to prevent goods produced using forced labor from entering the UK market. This should establish (1) how the risk of forced labor in supply chains will be identified, (2) who is responsible for identifying forced labor risks in supply chains and what is done with this information, (3) who is responsible for preventing the importation of goods likely to be exposed to forced labor and if necessary confiscating goods and (4) what resulting processes will follow once goods are confiscated.
- The import ban must clarify that no company that uses or allows state-imposed forced labor in its supply chains can import goods into the UK. The Committee expressed the view that the Government’s China Audit missed an opportunity by not publicly setting out an approach to addressing state-imposed forced labor in China.
- The UK’s import ban should include a rebuttable presumption for goods linked to regions where the UK Government considers there to be state-imposed forced labor. The US Uyghur Forced Labor Prevention Act (discussed here) and Countering America’s Adversaries Through Sanctions Act (discussed here) take this approach.
- The UK’s import ban should establish or designate a responsible body to oversee the implementation of the import ban by facilitating data sharing and coordinating activity between different law enforcement agencies.
Access to Justice
The Committee concluded that it is currently too difficult for individual survivors to access UK courts when they have been subject to forced labor abroad in the supply chains of UK companies.
Recommendation
- A civil cause of action of failure to prevent forced labor should be created. The burden of proof would be on the company to show it had adequate procedures in place to prevent the forced labor, such as due diligence processes. Companies unable to satisfy the burden of proof would be liable for compensation to victims.
