Eliminating Child Labor and Forced Labor in Imported Agricultural Products

On April 12, the U.S. Department of Agriculture’s (USDA) Foreign Agricultural Service announced the opening of the public comment period on recommendations – made by the Consultative Group to Eliminate the Use of Child Labor and Forced Labor in Imported Agricultural Products – for voluntary private-sector monitoring and verification of child labor and forced labor in supply chains.  Click here to review the federal register notice, including recommendations, instructions on submitting comments, and information on the upcoming public meeting on May 12, 2011, in Washington, DC.

The Consultative Group was established by section 3205 of the Food, Conservation, and Energy Act of 2008 (“Farm Bill”), and FLA President & CEO Auret van Heerden was appointed to the Consultative Group in 2009 by Secretary of Agriculture Thomas J. Vilsack.  On December 15, 2010, the Consultative Group made recommendations for a set of program elements for inclusion in the voluntary company guidelines to be issued by the Secretary of Agriculture. The recommendations include (from the 2010 report):

  • Setting standards on child labor and forced labor that meet or exceed relevant International Labor Organization standards or national law, whichever is more stringent;
  • Mapping supply chains, beginning with the producers of each agricultural product or commodity, and identifying areas of child labor/forced labor risk along these chains;
  • Communicating the company’s standards, rights, expectations, monitoring and verification programs, remediation policies, and complaint process to suppliers (managers, supervisors, staff) throughout its supply chain as appropriate, including to workers, unions, producers, civil society groups and other relevant stakeholders;
  • Ensuring that a safe and accessible channel is available to workers and other stakeholders to lodge complaints, including through independent monitors or verifiers.
  • Monitoring of company supply chains through periodic auditing by competent and qualified auditors, with a special emphasis on identified areas of risk;
  • Developing and implementing a remediation policy/plan that addresses remediation for individual victims as well as remediation of company and/or suppliers’ systems and processes;
  • Periodically conducting internal reviews to check the company’s results against its own program goals; and
  • Making available to the public information on the company’s monitoring program and its process to remediate/improve performance.


The Consultative group also recommended independent third-party review, which is an important aspect of FLA’s work.  According to the federal register, companies may chose independent third-party monitoring or verification to “ensure that they have robust systems in place to reduce the likelihood that child or forced labor is being used in their supply chains.”  See Section III towards the bottom of this page for detailed recommendations on third-party monitoring procedures.

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