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Executive Summary

A.     Congressional Mandate

This is the fourth Congressionally-mandated report in the international childlabor series of the Department of Labor's Bureau of International Labor Affairs (ILAB). It analyzes voluntary efforts, particularly labeling initiatives, to inform consumers that measures are being taken to prevent the use of child labor in the production of hand-knotted carpets, leather footwear, soccer balls and tea. The report was mandated by the Omnibus Consolidated Appropriations Act of 1997, P.L. 104-208.

B.     Overview

In recent years, frequent and often unsettling media reports have made consumers in the United States and other industrialized countries more aware of the possibility that the goods they purchase could have been produced by a child under exploitative conditions. In response, several non-governmental organizations (NGOs) and corporations are communicating child labor policies to consumers through labels.

Nine consumer labeling programs addressing child labor in the hand-knotted carpet, leather footwear, soccer ball and tea industries are discussed in detail in the report. To the extent that information is available about other labels, it is also discussed. The analysis considers the following elements of labeling programs: (1) the physical label; (2) claims behind the label; (3) the administration of a labeling program; (4) transparency for the public; (5) monitoring; and (6) enforcement.

While this report focuses primarily on the emerging child labor consumer labels, it also describes other efforts initiated by businesses to develop and implement policies prohibiting child labor. In most of the industries surveyed for this report, associations of manufacturers, importers, and sometimes retailers have developed or are now developing codes of conduct. Some companies are also changing production processes to prevent child labor and more easily monitor supplier adherence to their child labor policies.

To gather information on the labeling programs and other private sector efforts to combat exploitative child labor, the Department of Labor held public hearings, contacted hundreds of interested parties, and conducted site visits to Brazil, China, India, Kenya, Mexico, Nepal, Pakistan and Tanzania. The Department of Labor also conducted a small, non-random voluntary survey of 49 U.S. importers and retailers. Although companies surveyed were chosen to represent a broad spectrum of the hand-knotted carpet, leather footwear, soccer ball and tea industries, the findings from the survey of importers and retailers cannot be generalized to firms beyond the respondents. A company or program's inclusion in this report does not constitute endorsement by the U.S. Department of Labor of any product, service, company or program.

C.     Child Labor and Consumer Labeling
         Programs in the Production of
         Hand-Knotted Carpets,
         Leather Footwear, Soccer Balls, and Tea.

Little reliable information exists on the actual number of children working in a particular economic activity, and there are no reliable data on the precise level of child labor associated with the production of items covered in this report. Over the years, however, there have been numerous reports of child labor being used in the hand-knotted carpet, leather footwear, soccer ball and tea industries. Many of these reports were documented by ILAB in volumes I and II of By the Sweat and Toil of Children.

The research and field visits conducted for this report indicate that the majority of children who work in these four industries perform labor-intensive tasks and are found in subcontracting or smallholder operations, including homework, rather than in large factories and well organized workshops or agricultural estates. While poverty remains a common explanation given for the persistence of child labor, lack of access to quality education and inadequate law enforcement perpetuate a cycle of child labor and poverty in many countries.

         1.         Hand-Knotted Carpets

Child labor continues to be a problem in the hand-knotted carpet industries of India, Nepal, and Pakistan. Children are involved in almost every aspect of carpet production, including dyeing, spinning, and unraveling yarn and weaving, knotting, cutting, and washing carpets.

Nearly all hand-knotted carpets are made for export. The leading carpet exporting countries are Iran, India, China, Pakistan, Turkey, Nepal and Egypt. The United States and Germany are the world's leading importers. The United States imported $329 million worth of hand-knotted carpets in 1996. India is the largest single source of U.S. imports of hand-knotted carpets, followed by China.

                     a.       Consumer Labeling Programs in
                               the Hand-Knotted Carpet Industry

The main child labor labeling programs for carpets are: (a) RUGMARK®; (b)Kaleen; (c) STEP; and (d) Care & Fair. RUGMARK® and Kaleen are product labels that are affixed to individual carpets. STEP and Care & Fair are company certification programs. Participating companies use the labels for advertising and marketing purposes, but not on individual carpets.

RUGMARK: Established in India in September 1994 and expanded to Nepal the following year, RUGMARK® is a private, voluntary certification program providing market-driven incentives for carpet manufacturers to produce without child labor. Efforts are now underway to establish RUGMARK® in Pakistan.

The principal objectives of the program are to: (1) organize individuals and companies in the carpet industry to cease the use of child labor; (2) establish an independent, professional and internationally credible monitoring and certification system for carpets manufactured without child labor; and (3) rehabilitate and educate former child carpet workers. The program is funded primarily by a combination of exporter and importer fees based on the value of the carpets. The monitoring and certification programs of the RUGMARK® initiative, although still new, are the most developed, with an extensive system of checks and balances.

The RUGMARK® label, placed on the back of each carpet, displays a carpet with a smiling face. As of June 1997, the Indian RUGMARK Foundation had certified the export of about 636,000 labeled carpets from 164 licensed producers/exporters. As of May 1997, the Nepalese program had 27 licensees and exported about 6,500 certified carpets.

In both India and Nepal, the RUGMARK® program is monitored and enforced through an elaborate system of licensee approval, random inspections and carpet tracking. During the production of each carpet, professional RUGMARK® inspectors can make unannounced visits at any time to verify no child labor is being used.

As of June 1997, the Indian RUGMARK Foundation reports having conducted a total of 22,800 inspections of 18,400 registered looms. During the course of these investigations, 1,060 children were found working illegally. As of August 1997, the Nepal RUGMARK Foundation had registered 1,868 looms and made 1,754 unannounced visits to licensees' facilities, finding 143 children illegally working at looms. RUGMARK-India operates two educational facilities for children. RUGMARK-Nepal operates three rehabilitation schools.

Kaleen: The Kaleen labeling program was established in India in June 1995 by the Carpet Export Promotion Council (CEPC), a quasi-governmental body which oversees the mandatory registration of all Indian carpet exporters and issues export licenses. The CEPC was established by the Indian Ministry of Textiles and is funded through direct grants from the Ministries of Textiles and Commerce and subscription income from industry members. As of mid-1997, the CEPC had over 2,000 exporter members.

The Kaleen labeling system is based on: (1) a commitment of the exporters towards elimination of child labor through a code of conduct; (2) registration of looms by the exporters; (3) inspection by an independent agency and punitive action against defaulters; (4) collection from all exporters of a fee for child welfare activities; and (5) periodic review by the Steering Committee headed by the Development Commissioner for Handicrafts.

The Kaleen label consists of a triangle with an inscription along the edges stating "The Hallmark of Commitment for Child Welfare," and "promoted by the Government of India, Carpet Export Promotion Council." As of May 30, 1997, 572,000 Kaleen labels had been issued to 219 CEPC members, roughly 10 percent of total membership.

Monitoring for compliance with the CEPC code of conduct and the registration requirement consists of member self-monitoring and inspections of a small share of loom sites by a private firm. During the first year of inspections, about 100 child laborers were found. The CEPC is currently providing partial funding for twelve schools. In addition, the CEPC is considering a proposal to establish a boarding school facility for former bonded child laborers.

STEP: The STEP Foundation for fair conditions in carpet production and carpet trade, a joint initiative of the Swiss Association for a Clean Oriental Carpet Trade and five NGOs, was established in October 1995. STEP has programs in India, Nepal, and Pakistan and plans to establish the program in Iran, Morocco, Egypt and Turkey. The program promotes the progressive elimination of abusive child labor. It targets work and health conditions of all carpet workers as well as environmental concerns. STEP's administrative and social program costs are borne by European licensees.

Unlike RUGMARK® and Kaleen, the STEP program certifies companies through its label, which is displayed in retail stores but not placed on individual carpets. The label contains the word STEP superimposed on a Chinese symbol for long life. It is intended to signal that the bearer is attempting to implement STEP employment and environmental standards by importing carpets only from STEP-registered producers.

Carpet producers and exporters may participate in the STEP program through inclusion on the STEP register. Registered carpet manufacturers and their subcontractors must agree to allow regular, unannounced inspections by STEP and/or affiliated NGOs. The STEP register includes a total of 16 carpet suppliers. STEP representatives in producing countries are responsible for monitoring, outreach and social support functions. While the STEP representative in Nepal conducts regular visits to registered producers, the STEP representative in India currently does no monitoring. The program is not yet fully operational in Pakistan.

Care & Fair: Care & Fair is an association of German carpet trade professionals founded in September 1994. Care & Fair has nearly 600 members, including carpet and furniture retailers, carpet importers, and wholesalers in Germany, the United Kingdom, the Netherlands, and Luxembourg. The organization and its programs are financed by member fees.

Like the STEP program, Care & Fair is a company certification program. Its members have obligated their carpet suppliers in India and Nepal to honor the terms of Care & Fair's Statement of Demands, a code of conduct which includes eliminating child and bonded labor and contributing to health and education programs for carpet workers and their families. Members may purchase Care & Fair advertising and demonstration materials confirming their membership in the association. The Care & Fair logo, which appears on these materials, consists of a mosque-shaped design depicting two smiling children who appear to be riding on a flying carpet.

The Association does not attempt to inspect the operations of member companies or guarantee that the carpets they handle are child labor-free. It relies completely on a moral commitment, arguing that it is impossible to monitor looms spread over large areas. Care & Fair provides funding to a variety of social programs, including schools and hospitals, for carpet workers and their families.

Other Labeling Programs: The Export Promotion Bureau of the Government of Pakistan has indicated interest in establishing a labeling program to certify child labor-free manufacture of hand-knotted carpets. At the time research for this report was completed, the details of a child labor monitoring and certification system had not been worked out.

As a result of the widespread public awareness of the use of child labor in the carpet industry, it has become common for individual manufacturers, exporters, or importers to affix their own child labor-free label on their carpets without ensuring adequate monitoring procedures are in place. Such labels have been found on Indian carpets for sale by both small and large U. S. retailers.

                     b.       U.S. Carpet Importers' and Retailers'
                               Policies on Child Labor

Corporate policies on child labor are a relatively new phenomenon among U.S. carpet importers and retailers. In 1994, the Oriental Rug Importers Association (ORIA) developed a voluntary policy addressing child labor in the production of carpets that encourages manufacturers to "take every reasonable step to ensure, to the maximum extent possible, that the carpets are not made by illegal child labor, as defined by national law."

The Department of Labor gathered information on private sector efforts to combat child labor through a voluntary survey of 15 U.S. importers and retailers of hand-knotted carpets. Nine responses were received.

  • Six respondents indicated they are either participating in a labeling program or using a code of conduct with a provision on child labor.
     
  • The frequency and thoroughness of the monitoring procedures vary among respondents. Most monitoring consists of occasional visits to production sites by a representative of the U.S. importer.

         2.         Leather Footwear

Reports of child labor in the leather footwear industries of Brazil, India, Mexico, and Pakistan document children cutting, hammering, folding, gluing, marking, hand-sewing, and sanding the soles of shoes. Children tend to work in home-based enterprises where the subcontracting of shoe production is generally found.

In 1996, the United States imported 602 million pairs of leather footwear with a value of $8.2 billion. Two-thirds of U.S. leather footwear imports came from China and Brazil. China alone accounted for about 53 percent of all leather footwear imports by quantity. U.S. production of leather footwear is rather limited.

                     a.       Consumer Labeling Programs in
                               the Leather Footwear Industry

The main child labor labeling programs now operating in the leather footwear industry are the Abrinq Foundation for Children's Rights and the Pro-Child Institute, both of which are based in Brazil.

Abrinq Foundation for Children's Rights: The Abrinq Foundation for Children's Rights (Abrinq) is a non-profit organization established in 1990 by members of Brazil's Association of Toy Manufacturers. Abrinq's mission is to "move and mobilize society regarding childhood matters, promoting social and entrepreneurial engagement to address child welfare issues, through political actions in defense of children's rights and through exemplary actions which may be disseminated and multiplied."

In April 1995, the Abrinq Foundation created the Child-Friendly Company Program (Programa Empresa Amiga da Criança) aimed at eradicating child labor and promoting child-friendly policies in a number of Brazilian industries. This program, which includes a labeling component, encourages companies to eliminate child labor and invest in projects which improve the quality of children's lives. The program is financed through a grant provided in 1995 by a private company. Of the 380 companies participating in the labeling program, approximately 40 are manufacturers of leather footwear.

Companies certified by Abrinq as "child-friendly" are allowed to use the program label, which reads: "Child-Friendly Company – An Initiative of the Abrinq Foundation for Children's Rights." Child-Friendly companies may place the label on products, packaging, or a company's advertisement and promotional materials. Although a number of companies in the program export goods to the United States, there are currently no products being exported to the United States with Abrinq's Child-Friendly Company label.

The Foundation has specific eligibility criteria that companies must meet prior to joining the labeling program. These include: (1) making a formal commitment not to use child labor, as defined by Brazilian law; (2) promoting this commitment to its network of suppliers and clients; and (3) creating or supporting programs to educate and train children. In industries with a high incidence of child labor (e.g., sugar and footwear production), Abrinq consults with its network of partners, which includes labor unions, employers associations, NGOs, and public officials, before certifying a company. The Foundation does not have any formal monitoring procedures, but conducts investigations of alleged child labor violations by member companies. As part of the education and training component of the Child-Friendly Company Program, many companies provide child care services and sports/recreational facilities for after-school programs and fund professional and technical training projects.

Pro-Child Institute: The Pro-Child Institute (Instituto Empresarial de Apoio a Formação da Criança e do Adolescente "Pro-Criança") is a non-profit organization founded in November 1995 by the Footwear Industry Association of Franca, the Trade and Industry Association of Franca, and the Regional Delegation of CIESP (Centro das Indústrias do Estado de São Paulo), a state-wide industry association. In October 1996, the Pro-Child Institute launched the "Program for the Prevention and Eradication of Child Labor in the Footwear Industry."

One of the components of this program was the development of a Pro-Child label which is placed on footwear products to indicate a company's adherence to the program's goals. The label reads: "Pro-Child Institute – No Child Labor was Used in the Manufacture of this Product." Companies participating in the program must: (1) make a formal commitment not to use child labor; (2) not sub-contract services with suppliers who use child labor; (3) encourage a no-child labor policy throughout their chain of production; (4) be a contributing member of the Pro-Child Institute; (5) adhere to the Institute's regulations regarding the use of the label; and (6) place a no-child labor clause in contracts with other manufacturers and encourage them to also become members of the Pro-Child Institute. The Institute's operational costs, as well as the labeling program, are financed through private-sector contributions.

As of January 1997, the Pro-Child Institute had certified 67 companies in Franca. Implementation and monitoring are carried out by the Institute's staff. The Institute's monitoring procedures include announced and unannounced visits to companies, regular meetings with companies, and periodic reports on the labeling program. The Pro-Child Institute has developed a series of educational and social projects for children and adolescents. These projects include a health center for adolescents, resource centers, vocational training centers, and recreational programs.

                     b.       U.S. Leather Footwear Importers' and
                               Retailers' Policies on Child Labor

There is significant use of voluntary codes of conduct or other policies prohibiting child labor among U.S. importers and retailers of leather footwear, as well as industry associations. In April 1997, the U.S. Apparel Industry Partnership, composed of leaders from the U.S. footwear and apparel industries, labor unions, and consumer, human rights, and religious groups, agreed on a workplace code of conduct.

Sixteen companies responded to a voluntary survey of 20 U.S. producers, importers, design/marketing firms, and retailers of leather footwear products. None of the survey respondents participate in a labeling program or import footwear labeled as child labor-free. All companies responding to the survey have developed and implemented a corporate policy prohibiting the use of child labor in the manufacture of their products.

  • Foreign manufacturers' awareness of U.S. footwear importers' corporate policies on child labor varies from country to country. In Brazil, small leather footwear companies were not aware of the child labor policies of U.S. importers. Although awareness was limited among large companies interviewed, most of these companies were participating in a child labor-free labeling program. Awareness was mixed in China and India, while in Mexico, nearly all of the footwear producers interviewed were unfamiliar with the codes of conduct of their U.S. importers.
     
  • Monitoring procedures used to oversee the implementation of the codes of conduct also differ among the survey respondents. Four respondents indicated that they conduct pre-screening inspections to ensure foreign suppliers have the capacity to implement their codes of conduct. All respondents indicated they monitor overseas facilities for compliance with their corporate policies.
     
  • Most survey respondents indicated that willful non-compliance with the company's policy may result in canceled orders or termination of the business relationship. Only a few respondents said they had found violations of their codes of conduct. Two stated they have handled child labor problems by changing their methods of production to reduce or completely eliminate subcontracting.

         3.         Soccer Balls

The use of child labor in the production of hand-stitched soccer balls has been documented primarily in Pakistan and India. The hand-stitching of soccer balls in Pakistan is decentralized in homes and small village workshops, where adults and children commonly work side by side. Working arrangements in India are very similar.

In recent years, soccer has become increasingly popular in the United States. Strong growth in the volume of U.S. imports of soccer balls reflects this trend. In 1996, some 75 percent of those imports came from Pakistan, where most balls are produced around the city of Sialkot. Soccer balls are not produced in the United States.

                     a.       Consumer Labeling Programs in
                               the Soccer Ball Industry

Adverse publicity in the United States and Europe regarding Indian and Pakistani children stitching soccer balls prompted some U.S. importers to adopt labels informing consumers that their products have been produced in a child labor-free environment. In some cases, these programs are accompanied by changes in production processes to prevent the employment of children.

Reebok: In 1992, Reebok International Ltd. (Reebok) issued a code of conduct prohibiting the use of child labor in the manufacture of Reebok products. Recognizing the high incidence of child workers in the Pakistani soccer ball industry, Reebok recently built a soccer ball manufacturing plant in Sialkot where all production, including stitching, is centralized.

Soccer balls produced for Reebok in Sialkot bear the following label: "Guar-antee: Manufactured without child labor." The three major elements of Reebok's program are: (1) containment of all production in the new facility, in which all work on Reebok balls is performed by workers age 15 or older; (2) external monitoring to ensure that children are not entering the workplace and soccer ball panels are not leaving the factory for stitching; and (3) support of education and/or vocational education training for children in the Sialkot region.

Reebok has hired three independent monitors to check the effectiveness of the program. Two monitors inspect the factory, interview workers, maintain ties to the local community, and visit surrounding villages to ensure no Reebok balls are stitched outside the factory. The third monitor was hired to audit factory records. In addition to the new factory and monitoring program, Reebok is planning an educational project in Sialkot.

Baden Sports: In 1997, Baden Sports eliminated most hand-stitching of its soccer balls when it began importing machine-stitched soccer balls from a manufacturer in China. Soccer balls imported by Baden from China bear the label: "Certified: No Child or Slave Labor Used on This Ball." Baden requires written certification from the manufacturer that child labor is not used in the manufacture of Baden products and maintains access to personnel records at the factory. A Baden representative monitors the manufacturing facility to check for quality, design, and child labor.

Other Labeling Programs: Research conducted for this report identified seven other labels stating soccer balls were not made by children. Only one of the labeling programs, sponsored by Dunkin' Donuts, has a monitoring and certification component. The other programs base their child labor-free claim on their participation in the Partner's Agreement to Eliminate Child Labor in the Soccer Ball Industry in Pakistan. This agreement, signed in February 1997 by representatives of the Sialkot Chamber of Commerce and Industry, the International Labor Organization (ILO), and UNICEF, aims to eliminate child labor in soccer production in the Sialkot area. The Agreement's prevention and monitoring program is not yet fully operational.

                     b.       U.S. Soccer Ball Importers' and
                               Retailers' Policies on Child Labor

Voluntary codes of conduct prohibiting child labor are also becoming more common in the soccer ball industry. Such codes have been adopted by soccer organizations, sporting goods manufacturers, importers, and retailers of soccer balls. In September 1996, the International Federation of Football Associations (FIFA) announced an agreement with three international unions on a Code of Labor Practice, including a ban on child labor, for all goods bearing its logo. However, the FIFA Code of Labor Practice has not been embraced by soccer ball manufacturers or importers.

  • Some U.S. importers and retailers of soccer balls have issued their own codes of conduct prohibiting the use of child labor. Nine companies responded to a voluntary survey of seven U.S. importers and 3 retailers of soccer balls.
     
  • Seven of the nine companies responding to the survey have adopted some type of written policy prohibiting the use of child labor. In cases where the company purchases and/or sells numerous products, the code applies to all the products, not just soccer balls.
     
  • All seven importers have endorsed the Partners' Agreement in addition to issuing their own individual corporate policies against child labor.
     
  • Only three respondents — all importers — indicated that they communicate their no child labor policy directly to consumers. The remaining importers and retailers either have no method to inform consumers of their policy or have suppliers that inform consumers through a label.
     
  • Seven respondents — all importers — send company staff, buyer agents or other parties to inspect facilities to verify that suppliers are actually implementing their code of conduct.

         4.         Tea

Child labor is no longer common on large commercial estates in Brazil, India, Kenya, Nepal, and Tanzania, but may be more pervasive in the smallholder sector in these and other countries. In some cases, smallholder producers sell their output to nearby estates through outsourcing arrangements. Most allegations of child labor in the tea industry involve the labor-intensive functions of plucking, weeding, hoeing, and nursery work.

With the obvious exception of water, tea is the most widely consumed beverage in the world. World production is largely concentrated in a few countries. In 1995, India, China, Sri Lanka, Kenya, Indonesia, and Argentina accounted for over 75 percent of world production. U.S. tea imports in 1996 were valued at $132.1 million. Only a small amount of tea is grown commercially in the United States, on a plantation in South Carolina.

                     a.       Consumer Labeling Programs
                               in the Tea Industry

In the tea industry, child labor labeling appears to be limited to fair trade labeling organizations. These programs originated in Europe and today are found in a number of tea consuming countries, including the United States. Fair trade labels inform consumers that products have been produced and traded under certain conditions.

The basic criteria used by fair trade labeling organizations are the following: (1) the payment of a fair price, which covers production costs plus a fair trade premium that flows to the actual producers; (2) participation by the actual producers in decisions regarding use of the fair trade premium; (3) provisions for advance payment or credit so that producers do not go into debt before sales can be realized; and (4) the promotion of longer term trading relationships so producers can plan for the future with some security. In addition, the commercial plantations producing fair trade tea are prohibited from employing children under the age of 14.

Tea importers and retailers pay a licensing fee for the use of a fair trade label and the services associated with it, such as promotion, marketing, and monitoring. Licensees place fair trade labels directly on tea boxes, individual tea bags, and/or tags.

The fair trade labels (including Max Havelaar, TRANSFAIR, and the FairTrade Mark) consist of a logo and an explanation of fair trade labeling but contain no specific written claims regarding child labor. Licensees can purchase labeled tea from any producer included on the international tea producer register, which is a list of approved sources. Producers must agree to give monitors free access to their estates and make available any records that might be required in order to verify information provided.

                     b.       U.S. Tea Importers', Packers', and
                               Retailers' Policies on Child Labor

Codes of conduct are not common in the U.S. tea industry. The Tea Association of the U.S.A., whose members account for approximately 80 percent of the U.S. tea trade, has stated that in both major and small tea producing countries, prohibitions against child labor are spelled out in national laws or voluntary industry standards. The Tea Association has indicated that member companies will "encourage all the tea producing countries to require strict adherence to all ILO standards and/or all applicable local labor legislation."

In an effort to assess the extent to which companies in the U.S. tea industry have responded to concerns about child labor through implementation of codes of conduct or other formal policies, the Department of Labor conducted a voluntary survey of 10 U.S.-based importers, packers, and retailers of tea.

The five U.S. tea importers, packers, and retailers that returned reportable survey responses to the Department of Labor were generally unaware of the use of child labor in overseas tea estates. Some companies reported they had never perceived child labor to be an issue in the industry and had never observed children working on tea plantations. None of the five companies returning reportable responses participates in a labeling system or has a code of conduct or formal policy prohibiting the use of child labor.

D.     Conclusions and Recommendations

The labeling programs described in this report are relatively new. Most are barely getting under way after an initial period of organization, and some are not being used on products sold to U.S. consumers. Because the child labor labeling programs are recent, and definitive data on costs and benefits as well as consumer demand are not available, this report has not attempted to make quantitative assessments of their effectiveness.

The labels vary significantly in meaning and scope. While some labels are meant to provide assurances that goods have not been made by children, others solely signify that the producers, importers, or exporters of goods are contributing to social programs for workers and their families. The monitoring mechanisms employed by the various programs vary from rigorous monitoring and inspection by external entities to no monitoring at all.

Credibility in the eyes of the consumer is an issue of paramount importance for labeling programs. One way credibility can be maintained is through monitoring of production facilities, including those of subcontractors. Child labor in hand-knotted carpets, leather footwear, soccer balls and tea is most often associated with production by households, small workshops and smallholder plantations. Unless there is a monitoring program that addresses production by these units, child labor-free claims cannot be guaranteed.

In addition to the nine labeling programs examined in detail, this report has also briefly described labeling programs operated by individual companies. These are primarily in the carpet and soccer ball industries, where such labels are becoming increasingly common. While these labels may indicate a product is child labor-free, no information is provided to consumers on whether these claims are backed up with adequate monitoring. Some importers and retailers selling labeled soccer balls, for instance, do not have a mechanism in place to confirm the veracity of the claims made by the producers and rely on membership of their Pakistani manufacturers in the Partners' Agreement. Since the internal and external monitoring programs of the Partners' Agreement are not yet fully operational, it is still premature for balls being produced in Pakistan to be labeled as child labor-free based solely on this Agreement.

The Department of Labor believes that labeling programs can be an effective, market-based response to consumers who do not want to support the exploitation of children in the production of goods for export.

Labeling programs can have several positive effects. In addition to satisfying consumer interest for labeled products, labeling programs can encourage a consensus among industry groups, NGOs, international organizations, and governments to combat child labor. Second, many labeling programs raise funds for educational and rehabilitation programs for former child workers. Finally, labeling programs can have an impact on reducing child labor in targeted industries, especially when these programs contain effective and transparent monitoring and enforcement procedures.

To increase the effectiveness of voluntary labeling programs to eliminate child labor, the U.S. Department of Labor recommends that U.S. companies consider whether some additional voluntary steps might be appropriate:

1. U.S. importers and retailers should consider further support for labeling efforts that inform consumers that a product is made without the use of child labor.

Labels can convey valuable information to consumers seeking child labor-free products. U.S. importers and retailers who have not implemented a labeling initiative should consider the benefits that labels may offer not only to consumers but to their own corporate image. By implementing a labeling initiative, U.S. importers and retailers may also benefit from an increase in consumer confidence.

2. U.S. importers, retailers, and administrators of labeling programs should consider working to increase the availability of labeled products in U.S. retail outlets.

Products labeled as child labor-free are not widely available in the United States. U.S. importers and retailers should consider taking steps to increase the number and variety of labeled products that are available so that consumers can exercise the option of purchasing labeled goods. Program administrators should consider increasing efforts to inform importers, retailers, and consumers about their labels.

3. Administrators of labeling programs should consider how to ensure that the claims they make about child labor are backed up with appropriate monitoring.

The integrity of a child labor-free label is best maintained through effective monitoring procedures. Some importers, particularly of hand-knotted carpets and soccer balls, appear to be placing their own child labor-free labels on products without first ensuring that adequate monitoring systems are in place to substantiate such a claim. If exploitative child labor is discovered in the facilities where such products are made, the use of such labels could result in a loss of credibility and consumer confidence.

4. Administrators of labeling programs should consider further steps to ensure that monitoring procedures cover sub-contracting arrangements.

Child labor is most often found in sub-contracting or outsourcing arrangements, including production by households, small workshops and smallholder plantations. If monitoring procedures do not cover these units, child labor-free claims may be misleading.

5. All parties should consider whether there would be additional benefits in adopting more standardized child labor labels.

Many existing child labor labels consist of a logo with little if any text explaining their significance. This makes it difficult for consumers to discern whether a labeled product is child labor-free. Furthermore, the existence of several labels for the same product, each potentially making different claims, may add to consumer confusion. It may be worthwhile for interested parties to consider the creation of a mechanism to standardize labels for similar products. Such a mechanism could support the development of generally accepted labeling and monitoring standards.


This report was produced by the staff of the International Child Labor Program and is published by the U.S. Department of Labor, Bureau of International Labor Affairs.

Acknowledgements