U.S. trade enforcement is combating the use of forced labor. The U.S. Department of Homeland Security's and businesses' efforts have decreased direct import of goods from the Xinjiang Uyghur Autonomous Region. Deeper ties to that region will be hard to find and eliminate; reducing the use of forced labor globally might be harder still. But these challenges do not negate the value of trying.

Combating Forced Labor in Global Supply Chains

Is U.S. Trade Enforcement Making a Difference, and Can It Do More?

Victoria A. Greenfield, Tobias Sytsma, Amanda Kerrigan, Maya Buenaventura, Karishma V. Patel, Max Steiner, Meghan Meredith, Andrew Scruggs, Lily Hoak, Kate Giglio, et al.

ResearchPublished Jan 8, 2025

The title of this report asks, "Is U.S. trade enforcement making a difference, and can it do more?" In short, the answer to both questions is "yes." Trade enforcement appears to be making a difference, but it can also do more, even if some aims of U.S. policy remain out of reach. Early evidence suggests that many stakeholders are taking note, and some are changing behavior in response. Focusing on the effects of the Uyghur Forced Labor Prevention Act of 2021, the authors' analysis suggests that a combination of the U.S. Department of Homeland Security's (DHS's) interventions and changes in businesses' behavior has led to a decline in direct imports of goods originating from the Xinjiang Uyghur Autonomous Region. However, deeper ties to that region will be difficult to root out and expunge, and reducing the use of forced labor globally might be yet more difficult. But these challenges do not negate the value of trying.

Key Findings

  • Trade enforcement requires active stakeholder participation.
  • Trade enforcement is bringing about change, but challenges remain.
  • Trade enforcement is valuable despite inherent obstacles.
  • Trade enforcement comes with costs.
  • DHS can use indicators to track progress and unintended consequences.
  • DHS needs enough of the right resources.
  • DHS and its stakeholders would benefit from better information.

Recommendations

  • Look for opportunities to encourage robust stakeholder participation by improving the flow and quality of information.
  • Consider options for taking a more comprehensive approach to combating the use of forced labor in global supply chains.
  • Consider options for mitigating unintended consequences.
  • Work with other federal agencies to track indicators of progress and unintended consequences over time.
  • Develop evidence with stakeholders to inform public debates on trade enforcement.
  • Continue to make the case for funding and staffing, both of which likely need to increase.

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Citation

RAND Style Manual

Greenfield, Victoria A., Tobias Sytsma, Amanda Kerrigan, Maya Buenaventura, Karishma V. Patel, Max Steiner, Meghan Meredith, Andrew Scruggs, Lily Hoak, Kate Giglio, Daniel Hicks, and Jonathan W. Welburn, Combating Forced Labor in Global Supply Chains: Is U.S. Trade Enforcement Making a Difference, and Can It Do More? Homeland Security Operational Analysis Center operated by the RAND Corporation, RR-A2534-2, 2025. As of April 30, 2025: https://www.rand.org/pubs/research_reports/RRA2534-2.html

Chicago Manual of Style

Greenfield, Victoria A., Tobias Sytsma, Amanda Kerrigan, Maya Buenaventura, Karishma V. Patel, Max Steiner, Meghan Meredith, Andrew Scruggs, Lily Hoak, Kate Giglio, Daniel Hicks, and Jonathan W. Welburn, Combating Forced Labor in Global Supply Chains: Is U.S. Trade Enforcement Making a Difference, and Can It Do More? Homeland Security Operational Analysis Center operated by the RAND Corporation, 2025. https://www.rand.org/pubs/research_reports/RRA2534-2.html.
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This research was sponsored by the U.S. Department of Homeland Security (DHS) Science and Technology Directorate and U.S. Customs and Border Protection and conducted in the Infrastructure, Immigration, and Security Operations Program of the RAND Homeland Security Research Division.

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