Established by the 2008 Farm Bill, the Consultative Group to Eliminate the Use of Child Labor and Forced Labor in Imported Agricultural Products developed and made recommendations to the Secretary of Agriculture regarding guidelines to reduce the likelihood that agricultural products imported into the United States are produced with the use of child or forced labor. The Group ended its work on December 31, 2012.



The consultative group consisted of both government and non-government members, who served until December 2012.

  • Bama Athreya, Advisor, International Labor Rights Forum
  • Eric Edmonds, Associate Professor of Economics, Dartmouth University
  • Kimberly Elliott, Senior Fellow, Center for Global Development, Visiting Fellow, Peterson Institute
  • Bill Guyton, President, World Cocoa Foundation
  • Rachelle Jackson, Independent Consultant
  • Dennis Macray, Senior Sustainability Advisor, Theo Chocolate Company
  • Eric Biel, Associate Deputy Undersecretary for International Affairs (Acting), U.S. Department of Labor
  • Michael Posner, Assistant Secretary of State for Democracy, Human Rights and Labor, U.S. Department of State
  • Edward Potter, Director, Global Workplace Rights, Coca-Cola Co.
  • Margaret Roggensack, Senior Advisor for Business and Human Rights, Human Rights First
  • Auret Van Heerden, President and CEO, Fair Labor Association
  • Darci Vetter, Deputy Under Secretary for Farm and Foreign Agricultural Services, U.S. Department of Agriculture
  • Ann Wright, Deputy Under Secretary for Marketing and Regulatory Programs, U.S. Department of Agriculture


To reduce the likelihood that imported agricultural products are made with the use of child labor or forced labor, the Group developed a set of recommendations for practices importers may voluntarily follow in production, processing, and distribution. In addition, the Group advised that companies adopting these practices should seek independent, third-party review of their implementation.

The recommendations were presented to Secretary of Agriculture Tom Vilsack, who elected to adopt them as guidelines (April 12, 2011) without change.


Public Comments

The Consultative Group received the following public comments on the Guidelines published April 12, 2011:



March 29, 2010: Public Meeting —Washington, DC

A public meeting of the Consultative Group was held Monday, March 29th at the U.S. Department of Agriculture. The purpose of the meeting was to receive information and comments from organizations and the general public on the following issues:

  1. Examples of identification, monitoring, verification, and/or certification systems, or other models, that have been successful in reducing child labor and/or forced labor in the global supply chains within the agricultural sector or other industries;
  2. The roles and responsibilities that may be appropriate for the business sector and other stakeholders (governments, unions, nongovernmental organizations, and others) in establishing independent, third-party monitoring and verification systems for the production, processing, and distribution of agricultural products or commodities;
  3. Other information that would be useful to the Consultative Group in meeting its mandate to develop recommendations relating to a standard set of practices for independent, third-party monitoring and verification for the production, processing, and distribution of agricultural products or commodities to reduce the likelihood that agricultural products or commodities imported into the United States are produced with the use of forced labor or child labor.

June 7, 2012: Meeting of Consultative Group and Multi-Sector Stakeholders —Washington, DC

The Consultative Group solicited views from Group members, expanded engagement to additional stakeholders beyond the Group, and obtained further input focusing on (1) the challenges that may exist in implementing the Guidelines published in 2011, and (2) specific sectors in which they might be utilized. Most of the meeting participants, whether from government, business, civil society, or academia, brought experience dealing with other international labor issues and had engaged in other dialogues bringing together varied perspectives and stakeholders.


Annual Reports to Congress