US Tariff Threat on 54 Nations for Forced Labour: What Apparel Brands Must Audit in India & Other Sourcing Hubs

This article is for informational purposes only and does not constitute legal, compliance, or sourcing advice. Verify certification and regulatory requirements with the relevant standards body or counsel.

Editorial note: Reported by The Sourcing Desk editorial team. We cross-reference claims against standards-body publications, regulatory filings, and primary sourcing data. Published 2026-06-04.

The United States is advancing a proposal to impose an additional 12.5% tariff on goods imported from 54 countries, including India, Bangladesh, Vietnam, Cambodia, and Sri Lanka, on the grounds that those nations present elevated forced labour risk in their export supply chains. The measure would layer on top of existing duties and sits alongside enforcement of Section 307 of the Tariff Act of 1930 and the Uyghur Forced Labor Prevention Act (UFLPA), which already bars imports produced with forced labour from entering US commerce.

The proposal, reported by Apparel Resources in late May 2026, names India explicitly among the flagged nations. India is the second-largest apparel exporter to the US after China, shipping roughly $5 billion in garments annually. The tariff is framed as a trade-policy instrument to pressure governments into tightening domestic labour enforcement, but for sourcing teams, the practical effect is immediate: any shipment from a flagged country that cannot demonstrate a clean forced-labour audit trail becomes a financial liability.

The five Ws: the US government is the actor; the mechanism is a proposed additional import tariff; the affected parties are apparel brands, retailers, and their suppliers across 54 countries; the timing is mid-2026, with the proposal still moving through the regulatory process; and the reason given is inadequate national-level enforcement against forced labour in export manufacturing.

What this means for sourcing teams

Forced labour due diligence is the process by which a brand or importer verifies that no stage of its supply chain, from raw material through cut-and-sew, involves workers who are compelled to work under threat, debt bondage, or withheld wages. Under UFLPA, the burden of proof sits with the importer: US Customs and Border Protection (CBP) can detain a shipment and the importer must rebut a presumption of forced labour with clear and convincing evidence.

The 12.5% tariff proposal raises the stakes further. Even if a shipment clears CBP detention, the additional duty applies at the country level, meaning cost exposure is structural rather than case-by-case.

Sourcing teams should take the following steps now:

• Map every tier of the supply chain for all 54 flagged countries. Tier-1 factory audits are not sufficient. CBP has detained shipments because of forced labour at the yarn-spinning or cotton-ginning stage, not the cut-and-sew facility. The UFLPA Entity List, maintained by the Department of Homeland Security, names specific companies whose goods are presumed to involve forced labour. Cross-check all sub-tier suppliers against this list.

• Collect Social Compliance Audit (SCA) reports from accredited bodies. Sedex Members Ethical Trade Audit (SMETA), SA8000 (Social Accountability International), and the Business Social Compliance Initiative (BSCI) are the most widely recognised frameworks. A SMETA 4-Pillar audit covers labour, health and safety, environment, and business ethics. SA8000 certification requires third-party verification against ILO core conventions. Neither replaces a UFLPA rebuttal package, but both generate the documentary record CBP expects to see.

• For India specifically, pay attention to bonded labour and migrant worker recruitment. The ILO's 2022 Global Estimates of Modern Slavery identified South Asia as home to the largest share of forced labour in the world in absolute terms. Indian spinning mills have faced scrutiny over the Sumangali scheme, a form of deferred-wage contract labour targeting young women. Any Indian spinning or weaving supplier should be asked to produce payroll records, freedom-of-movement documentation, and recruitment-fee receipts showing workers paid no fees to obtain employment.

• Require suppliers to sign a Forced Labour Compliance Declaration and back it with audit evidence dated within the last 12 months. A declaration alone carries no weight with CBP.

• For cotton-containing products, consider traceability certification. The Textile Exchange's Responsible Wool Standard, Organic Content Standard (OCS), and the Global Organic Textile Standard (GOTS) all require chain-of-custody documentation from farm to finished fabric. While these are not forced-labour certifications per se, they generate the transaction certificates and scope certificates that help establish where fibre originated, which is the first question CBP asks when it detains a cotton shipment.

When comparing Indian suppliers, sourcing teams should look at manufacturers across the major export clusters: Tirupur (knitwear), NCR/Noida (woven), and Bengaluru (value basics). Suppliers with active GOTS scope certificates, SA8000 certification, or SMETA audit reports on file in the Sedex platform are better positioned to provide the documentation a UFLPA rebuttal requires. No single supplier should be treated as automatically compliant; the audit evidence is what matters.

What changed

The UFLPA has been in force since June 2022 and has primarily targeted Xinjiang-origin goods. CBP has detained over $3.5 billion in goods under UFLPA enforcement through early 2026, according to CBP's published UFLPA statistics. The new 12.5% tariff proposal is a separate, broader instrument. It does not require CBP to prove forced labour in a specific shipment; it applies at the country level based on a government-level risk assessment.

This is a meaningful shift. Previous US forced-labour enforcement was shipment-specific and required CBP to identify a nexus to a named entity or region. A country-level tariff moves the burden upstream: brands must now treat the entire sourcing relationship with a flagged country as carrying tariff risk, not just shipments linked to a known bad actor.

The proposal also arrives as the EU Corporate Sustainability Due Diligence Directive (CSDDD) is being transposed into member-state law, with the first wave of large companies facing compliance obligations from 2027. Brands selling into both the US and EU markets face converging due diligence requirements from two directions simultaneously.

Limitations and open questions

The 12.5% tariff proposal has not been enacted into law as of the date of this article. The regulatory pathway, whether through executive order, Section 301 of the Trade Act of 1974, or new legislation, has not been publicly confirmed. The list of 54 countries has been reported by trade outlets but has not been published in the Federal Register as a formal notice of proposed rulemaking. Sourcing teams should monitor the Office of the United States Trade Representative (USTR) and the Federal Register for formal publication.

It is also not yet clear whether the tariff would apply to all goods from flagged countries or only to product categories with documented forced labour risk. Apparel and textiles are the most exposed sector given their labour intensity, but the scope of the measure remains undefined.

The UFLPA Entity List is updated periodically, and DHS has not announced a timeline for adding entities from countries outside the Xinjiang region. Whether Indian spinning mills or other South Asian suppliers will appear on the list is an open question.

Finally, the relationship between the proposed tariff and any bilateral trade agreements, including the US-India trade framework currently under negotiation, has not been addressed in public statements from either government.

This article is for informational purposes only and does not constitute legal, compliance, or sourcing advice. Verify certification and regulatory requirements with the relevant standards body or counsel.