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Freshfields Sustainability

| 2 minute read

Forced Labour in supply chains - UK Parliament Committee calls for reform

A major new Parliamentary report on Forced Labour has found that UK law is failing to prevent goods tainted by forced labour from reaching British consumers, and that the UK risks falling behind its international partners when addressing this issue.

The report by the Joint Committee on Human Rights highlights that forced labour, which affects over 27 million people globally, remains deeply embedded in the supply chains of goods entering the UK. High-risk sectors for UK imports include electronics, garments, fish, timber, textiles, processed foods, solar panels, and critical minerals. 

Report finds weaknesses in current UK Law and Policy

The UK Government’s efforts to address forced labour in supply chains are currently spread across a “patchwork” of legislation, led by the Modern Slavery Act 2015. While the Modern Slavery Act requires transparency in supply chains, the duty does not impose any substantive obligations on companies to address or minimise human rights risks: a company can comply by disclosing that it has taken no action (although in reality, many companies choose to go ‘beyond compliance’ for other reasons, including to demonstrate human rights commitments to stakeholders). 

The report criticised these provisions, saying that the evidence supporting statements was weak and that enforcement should be strengthened. It also highlighted that, unlike in some jurisdictions (notably the United States), there is currently no comprehensive import ban on goods produced with forced labour, and enforcement agencies have not made active use of existing powers (like those in the Proceeds of Crime Act 2002) to seize affected goods. While additional obligations have been introduced through recent legislation – such as the Procurement Act 2023 and the Great British Energy Act 2025 – the Committee’s overall assessment was that the existing legal and regulatory frameworks are inadequate for confronting the complexity of abuses in global supply chains. 

Key Proposals for Reform

The Committee set out its ambitious blueprint for reform:

  1. Human Rights Due Diligence: The Committee calls for legislation within a year to introduce mandatory human rights due diligence duties for business and create a civil right for survivors to claim against companies.  Under the new legislation, companies would be required to proactively assess and address human rights risks throughout their supply chains. Enforcement would include stiff penalties for non-compliance—proportionate to company turnover—to create real incentives for action.
  2. Comprehensive Import Ban: The Committee suggests that the UK should implement an import ban similar to those in the US and EU, including the use of “rebuttable presumptions” for goods originating from high-risk regions (e.g., Xinjiang), shifting the burden onto importers to prove their goods are slave-free.
  3. Regulatory oversight: The report recommends that the legislative change should be supported by a well-resourced regulatory body that has proper powers and mandates for agencies like the Border Force and National Crime Agency.
  4. Access to Justice: The Committee recognises that survivors should have easier access to UK courts against companies whose supply chains force them into labour, backed by a new “duty to prevent” modelled on the Bribery Act. The survivor voice should be formally integrated into policymaking, as occurs in the US via its Human Trafficking Advisory Council.
  5. Public Sector and Procurement Reform: The Committee notes particular risks in public procurement—with the public sector spending £400 billion annually. It supports the new Procurement Act 2023 but calls for better guidance for the implementation of the legislation to ensure forced labour risks are properly managed in public contracting.

Given the advances of human rights legislation in other major economies, there is a widening gap that the Committee suggests, if unaddressed, risks the UK becoming a “dumping ground” for goods excluded elsewhere. Its proposed framework would bring the UK in line with current approaches to addressing forced labour in supply chains. 

Tags

europe, governments and public sector, human rights, regulatory