Many retail sellers and manufacturers doing business in California are subject to the website disclosure requirements of California’s Transparency in Supply Chains Act, effective since January 1, 2012. The new law requires a large group of firms in these sectors to disclose their efforts to eradicate slavery and human trafficking from direct supply chains.

Companies have responded with a range of compliance approaches. Selected website disclosures in the first 90 days of the Act’s application show initial compliance trends. Those companies subject to the disclosure requirements are imposing new requirements on their suppliers.

Uncertainty regarding best practices for disclosure under the Act remains because of the absence of guidance or enforcement action by California’s Attorney General. Existing and proposed federal legislation in related areas should be considered in reviewing and planning compliance.