Section 307 Forced Labor Import Prohibition: What Importers Need to Know

U.S. Customs and Border Protection (CBP) is widening its forced labor enforcement well beyond China. Since late 2025, CBP has issued orders against garment manufacturers in Jordan, a copper producer in Serbia, a manufacturer in Taiwan, and a salt producer in the Republic of Korea. In June 2026, it also published new operational guidance for importers setting out how far it expects them to trace their supply chains.

Each of those orders rests on Section 307 of the Tariff Act of 1930, which bans goods made wholly or in part with forced labor from entering the United States. The ban applies to the goods themselves rather than to the company that sold them, so a single tainted input anywhere upstream can stop a shipment at the border.

Here is what Section 307 prohibits, how CBP enforces it, how it relates to the Uyghur Forced Labor Prevention Act (UFLPA), and how importers can manage the risk.

What Is the Section 307 Forced Labor Import Prohibition?

Section 307 of the Tariff Act of 1930 is a U.S. law that bars goods made with prohibited labor from entering the country. Codified at 19 U.S.C. 1307, it applies to goods mined, produced, or manufactured in any foreign country with any of three kinds of labor:

• Forced labor: work a person is made to do under threat of a penalty and has not agreed to do voluntarily. Since 2000, the definition explicitly includes forced or indentured child labor.
• Convict labor: work performed by people serving criminal sentences.
• Indentured labor under penal sanctions: work under a contract the worker cannot leave without facing punishment.

Congress enacted Section 307 on June 17, 1930. For decades, a consumptive demand exception let goods made with forced labor into the country if U.S. production could not meet domestic demand. Congress removed that exception in 2016, and most modern enforcement of Section 307 stems from that change.

Section 307 is a ban, not a duty. CBP also does not have to prove a violation before it holds a shipment. The importer has to show what labor produced each component. For organizations with global supply chains, supplier labor conditions determine whether goods can enter the country at all.

What Does Section 307 Prohibit?

Section 307 prohibits any good made wholly or in part with forced, convict, or indentured labor, from any country and in any product category. If prohibited labor went into any input at any point in the supply chain, the finished product is barred, no matter how small that input is or where final assembly took place.

Under 19 CFR 12.43(b), an importer seeking the release of detained goods must trace where the goods and every component came from. It must also identify the kind of labor behind each stage of production and show it made every reasonable effort to find out. Knowing the direct supplier is not enough. The importer has to account for the labor behind each part of the product, down to the raw material.

Processing goods in a third country does not clear them either. When an importer submits proof for detained goods, the regulation asks for a certificate of origin signed by the foreign seller. If the goods were made wholly or in part in another country, it also asks for a second certificate from the last owner or seller there. Moving a portion of production elsewhere adds paperwork, but it does not remove the obligation.

The recent orders in Europe, the Middle East, and East Asia show how wide that reach is. CBP’s withhold release orders and Findings dashboard lists the producers and goods covered today.

What an importer usually controls	What Section 307 reaches
The direct supplier	Every entity at every stage of the supply chain, and the relationship between them
The finished article	Every component of that article, from raw material to finished good
The country of export	Every country where the goods were mined, produced, or manufactured wholly or in part
Goods named on the Department of Labor list	Downstream goods made with listed inputs, as well as the listed goods themselves

What Counts as Forced Labor Under Section 307?

Section 307 defines forced labor as work or service taken from a person under threat of a penalty, which the person has not offered to do voluntarily. Forced or indentured child labor is included.

CBP’s June 2026 operational guidance breaks that definition into three elements:

• Work or service: labor that forms part of the material production of the goods.
• Menace of any penalty: the worker faces a penalty, or the threat of one, for refusing the work.
• Involuntariness: the worker did not offer to do the work freely.

Because the first element is limited to material production, labor such as packaging, inspecting, and labeling falls outside the prohibition.

To assess the three elements, CBP’s Forced Labor Division uses the International Labour Organization (ILO) publication Indicators of Forced Labour. It sets out 11 indicators, including retention of identity documents, withholding of wages, and debt bondage.

How Does CBP Enforce Section 307?

CBP enforces Section 307 through the Forced Labor Division of its Office of Trade, under procedures set out in 19 CFR 12.42 to 12.45. Investigations often start with outside information: anyone can submit an allegation, including the reasons behind it, a description or sample of the goods, and any available facts about how they were produced.

When the evidence supports action, CBP has two main tools:

• Withhold release order (WRO): an instruction to ports to hold shipments that appear to fall under the ban. CBP issues a WRO when it has reasonable suspicion that goods were made with prohibited labor.
• Finding: a formal determination, published in the Federal Register and the Customs Bulletin, that goods were made with prohibited labor. CBP issues a Finding when it has probable cause, and a Finding allows CBP to seize goods rather than detain them.

Under the regulation, CBP can issue a WRO when available information reasonably, but not conclusively, indicates a violation. That means CBP can hold a company’s goods before any violation has been proven. As of June 30, 2026, CBP was enforcing 58 WROs and nine Findings. Section 307 Findings are the more severe of the two tools and carry different consequences for importers.

What Happens When Goods Are Suspected of Being Made With Forced Labor? 

When a shipment falls under a WRO, CBP detains it at the port of entry. The importer then has three months from the date of importation to take one of three steps:

1. Export the goods to another country.
2. Destroy the goods.
3. Request an admissibility review, in which the importer files evidence that the goods were not made with prohibited labor.

The importer pays storage costs for the whole period, whatever the outcome. In an admissibility review, CBP examines the documentation filed for that specific shipment, including certificates of origin, transport records, and tracing back to the raw material. If the evidence satisfies CBP, the goods are released; if not, they are excluded. Goods covered by a Finding follow a different path: CBP seizes and forfeits them, and the importer cannot export them.

Release does not close the matter. Even after a shipment enters U.S. commerce, CBP can order the importer to return the goods by issuing CBP Form 4647. CBP can send that demand up to 30 days after release, or up to 30 days after the conditional release period ends (the window in which CBP can still review released goods), whichever is later. The importer then has 30 days to return the goods. If it does not, CBP can claim liquidated damages from the importer’s customs bond equal to three times the goods’ entered value. Importers should have supply chain evidence on file before a shipment arrives, rather than trying to compile it after CBP asks for it.

Section 307 vs. UFLPA

The Uyghur Forced Labor Prevention Act, Public Law 117-78, does not create a second import ban. It creates a rebuttable presumption that certain goods violate Section 307, meaning CBP treats them as prohibited unless the importer proves otherwise.

The presumption covers goods mined, produced, or manufactured wholly or in part in China’s Xinjiang Uyghur Autonomous Region, or by an entity on the UFLPA Entity List. The Forced Labor Enforcement Task Force maintains that list; as of October 18, 2026, its most recent additions took effect on August 3, 2026.

	Section 307	UFLPA
Scope	Any country and any product	Goods linked to Xinjiang or to entities on the UFLPA Entity List
How detention is triggered	CBP issues an order once it has reasonable suspicion	The presumption applies automatically to goods in scope
Time to respond after detention	Three months under a WRO	30 days

What Does Section 307 Mean for Importers and Supply Chains?

Section 307 makes importers responsible for knowing the labor conditions behind every product they bring in. That responsibility builds on a duty importers already have under customs law. Under 19 U.S.C. 1484, importers must use reasonable care when they declare goods to CBP. In plain terms, they must take the steps a careful, informed importer would take to make sure what they report about a shipment, such as its origin and value, is accurate. CBP’s guidance says that duty extends to ensuring imported goods contain no materials made, wholly or in part, with forced labor.

Meeting that standard is hard because most importers cannot see far into their supply chains. They usually know their Tier-1 direct suppliers, but not the factories, farms, and subcontractors behind them. The Congressional Research Service (CRS) report points to three reasons forced labor is hard to trace past that first tier: global supply chains are complex, subcontracting is widespread and often relies on migrant or temporary workers, and third-party audits have limits. Section 307 does not lower the bar to account for that gap, and CBP can still ask for evidence down to raw materials.

Importers may also face forced labor under a separate measure: the 2026 Section 301 forced labor action. Under Section 301, the Office of the United States Trade Representative (USTR) can penalize trading partners over how they enforce their own bans on forced labor imports. The current action covers 60 economies, with additional duties of 10% or 12.5% that took effect on July 24, 2026 (91 FR 47318). Those duties do not affect admissibility, so a shipment can clear Section 307 and still owe the Section 301 duty. Neither measure requires an annual filing or a due diligence plan, and both can take effect at short notice.

How to Manage Section 307 Risk 

Managing Section 307 risk means building evidence about labor conditions across the supply chain before CBP asks for it. The four steps below focus on tracing those conditions through every component, stage, and country, and they form one part of a broader Section 307 compliance program.

1. Screen against published lists. CBP’s dashboard shows which producers and goods are already under enforcement. The U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor shows where forced labor has been documented by product and country. Since the Frederick Douglass Trafficking Victims Prevention and Protection Reauthorization Act of 2018, the list has also covered downstream goods made with tainted inputs. CRS counts 35 such downstream goods on the 2024 list, alongside at least 75 goods made with forced labor in 44 countries and areas.
2. Use the federal tools built for the purpose. ImportWatch is a data dashboard that helps businesses spot goods linked to abusive labor practices abroad and can be searched by country, product type, exploitation category, and year. SourcingStrong is a free tool built around an eight-step labor due diligence framework. CBP cites both in its operational guidance.
3. Assess suppliers against the ILO indicators. CBP generally does not consider an audit sufficient to reduce forced labor risk unless it specifically examines the ILO indicators, and it expects unannounced audits conducted by independent auditors.
4. Map, monitor, and verify the full supplier base. CBP’s guidance asks for supply chain mapping, supplier engagement, monitoring, remediation, and independent verification across every supplier. The resulting records must be comparable across suppliers and retrievable for each shipment, sometimes years after the sourcing decision.

For importers with large supplier bases, EcoVadis IQ Plus maps forced labor and other human rights risks across suppliers by country and industry, which shows where to focus screening and mapping first. EcoVadis Ratings and Vitals then assess suppliers’ labor and human rights practices, building a consistent, documented due diligence record that can be compared across suppliers. The EcoVadis report Forced to Act examines the gap between the conditions audits find and the conditions suppliers report.

Supplier assessments complement product-level traceability rather than replacing it. CBP decides admissibility based on the documents filed for each shipment, and no assessment alone makes an importer compliant with Section 307.

Sources last verified: All figures and links in this article were verified on October 18, 2026. 

FAQs

What goods are prohibited under Section 307?

Any goods mined, produced, or manufactured wholly or in part with convict labor, forced labor, or indentured labor under penal sanctions, from any country are prohibited under Section 307. The statute exempts no product and sets no minimum threshold for the share of a good that the prohibited labor accounts for.

Does Section 307 apply to components and raw materials?

Yes. Section 307 requires an importer to account for the source of the merchandise and every component, and for the character of the labor used at any stage of production, down to the raw material.

What happens if goods are detained under Section 307?

Good detained under Section 307 are held at the port of entry. The importer has three months to export them, destroy them, or file an admissibility review, and pays the storage costs throughout. Goods subject to a Finding are seized instead and cannot be exported.

How is Section 307 different from the UFLPA?

Section 307 is the prohibition itself. The UFLPA is a rebuttable presumption that certain goods violate it. Every UFLPA case is therefore a Section 307 case, while the reverse does not follow.