Earlier this week, a Holland & Knight alert discussed the recently passed Uyghur Forced Labor Prevention Act and U.S. Customs and Border Protection's (CBP) request for public comments on how best to ensure that goods made with forced labor are not imported into the United States. As anticipated in that alert, U.S. government scrutiny of forced labor continues to increase. Of note, the U.S. Trade Representative (USTR) announced on Jan. 25, 2022, that it will develop its first focused trade strategy to combat forced labor. Ambassador Katherine Tai announced the new plan at the first meeting of the President's Interagency Task Force to Monitor and Combat Human Trafficking convened by President Joe Biden.

The USTR strategy will include:

• a thorough review of existing trade policies and tools intended to combat forced labor
• an identification of gaps and weak points in U.S. trade policy vis-à-vis forced labor, including forced child labor
• the creation of an inclusive process that maximizes input from stakeholders such as labor organizations, civil society, survivors and the private sector
• the establishment of objectives, priorities, new tools and key action items to combat forced labor

In the coming months, expect USTR to prioritize forced labor in discussions with trading partners, as well as additional efforts to highlight the issue globally as the U.S. government intensifies its increasingly "whole of government" approach to combatting forced labor.