While enforcement may have taken a backseat to other trade priorities in 2025, now is a good time to ask whether your business is ready for an anticipated resurgence in forced labor enforcement activity. That’s the message from law firm ArentFox Schiff, in its latest report: “Navigating the Complexities of Forced Labor Laws: ArentFox Schiff’s 2026 Guide for Global Businesses.”
The report warns businesses of all kinds, including those in supply chain management, to get ready for a focus on enforcement to return, both in the U.S. and internationally, often in coordination between countries and jurisdictions. The authors say new industries and geographies will be put under the microscope, and that the U.S., will continue to use novel measures to combat forced labor.
International enforcement coordination will pick up, and technology will be key for both the efforts of governments to achieve enforcement, and importers’ supply chain due diligence efforts, the authors say.
“Regulators will continue to focus on automotive manufacturers, the electronics industry, critical minerals supply chains, and steel and aluminum processors,” said the report. “However, new targets are also emerging: electric vehicles (EVs) and their battery supply chains, pharmaceuticals, and medical devices. New Withhold Release Orders (WROs) and findings outside of China will also be issued.”
Companies should be aware of pending U.S. state forced labor laws, for example in California. States continue to propose forced labor laws that limit the ability of companies to sell to state governments, which are the largest purchasers in many states, the report warned.
Further, technology is likely to make enforcement easier and more rigorous. “Technology will be key for both government enforcement targeting and importers’ supply chain due diligence efforts. We expect the government to increasingly leverage technology and data analysis to target priority sectors. At the same time, companies can use evolving technologies to assist with forced labor diligence,” the report said.
“The window for proactive preparation is now. For businesses, the message is clear: A reactive approach to forced labor compliance is not viable,” said Angela M. Santos, ArentFox Schiff partner and customs practice leader, and one of the report’s authors. “Companies must proactively map their supply chains to identify exposure to high-risk regions and entities, implement robust due diligence programs, and prepare documentation sufficient to rebut the presumption of forced labor when goods are detained or excluded.”