List of Products Produced by Forced or Indentured Child Labor

ILAB maintains a list of products and their source countries which it has a reasonable basis to believe are produced by forced or indentured child labor, pursuant to Executive Order 13126. This List is intended to ensure that U.S. federal agencies do not procure goods made by forced or indentured child labor. Under procurement regulations, federal contractors who supply products on the List must certify that they have made a good faith effort to determine whether forced or indentured child labor was used to produce the items supplied.

The Department of Labor, in consultation with the Departments of State and Homeland Security, publishes and maintains the List. ILAB released its initial List in 2001, and has revised it several times since then. As of July 13, 2022, the EO List comprises 34 products from 26 countries.

Legal Authorities

The List is required by Executive Order 13126, "Prohibition of Acquisition of Products Produced by Forced or Indentured Child Labor." The procurement requirements related to products on the List are set out in a 2001 Federal Acquisition Regulation Final Rule.

Procedural Guidelines

ILAB develops the List using criteria and procedures established in its "Procedural Guidelines for the Maintenance of the List of Products Requiring Federal Contractor Certification as to Forced or Indentured Child Labor."

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Burma
  Teak

There are reports that children are forced to work in the production of teak in Burma. Forced child labor is found on teak plantations in the Thaton District, and particularly in areas near military camps. An NGO study reports that villagers, including children, from multiple villages are regularly mobilized by the military for forced labor to cultivate teak and other crops. The forced laborers are not paid for their work. 

Burmese Translation

Burma
  Rice

There are reports that children as young as age nine are forced to work in the production of rice in Burma. According to NGOs, villagers, including children, are forced to work planting and harvesting rice for the military camps. These children are forced to work on rotation year-round for the military, although most rice paddy cultivation occurs during the rainy season. Local officials and the military enforce the work orders, and workers cannot refuse to work, even if sick. The forced child laborers are not paid for their work, and the children are beaten if their work is considered to be of unacceptable quality. 

Burmese Translation

Burma
  Bamboo

There are reports that children as young as age 10 are forced to work in the production of bamboo in Burma. According to the ILO and NGOs, forced child labor is pervasive, particularly in Karen, Shan, and Arakan States near military camps, with children constituting up to 40 percent of forced laborers being used for a variety of activities, including the production of bamboo. Some of these children are sent by their families to fulfill a mandate imposed by the military that requires each household in a village to undertake specified forced labor activities. Villagers, including children, are forced by local officials and the military to work cutting bamboo for the military camps. The forced child laborers are not paid for their work, and face physical violence or other punishment if they refuse to work. 

Burmese Translation

Burma
  Rubber

There are reports that children as young as age nine are forced to work in the production of rubber in Burma. According to reports by NGOs, villagers, including children, are forced to work cultivating rubber plants in nurseries and on plantations for the military camps. Local officials and the military enforce the work orders. The forced child laborers are not paid for their work, and endure physical violence or other punishment if they refuse to work. 

Burmese Translation

Burma
  Beans (green, soy, yellow)

There are reports that children ages 15-17 work under conditions of forced labor in the production of beans in Burma. An NGO study documents children, as well as adults, forced by the military to work on rotation year round, planting and harvesting beans for the military camp. Local officials and the military enforce these work orders; the children cannot refuse to work, even if sick. 

Burmese Translation

Cambodia
  Bricks

There are reports that children are forced to produce bricks in Cambodia. According to international researchers and NGOs, numerous incidents of forced child labor have been reported in Cambodia. Reports estimate over 9.3 percent of brick workers are children. However, with upwards of tens of thousands of workers employed at brick kilns and the casual nature of work in brick kilns, this number is likely higher. A cycle of multi-generational debt bondage is created when adults are unable to pay back the high interest charged on loans offered by brick kiln owners and are forced to pass along outstanding debts to their children. Children either inherit or are born into debt bondage and are threatened with arrest or are forced to pay additional debt if they try to leave the brick kiln without repaying their debts in full.

Khmer Translation

China
  Electronics

There are reports that children ages 13-15 are forced to produce electronics in China. Based on the most recently available data from media sources, government raids, and NGOs, hundreds of cases of forced child labor have been reported in factories in Guangdong province, but the children are often from Henan, Shanxi, or Sichuan provinces. In some cases, children are forced to work in electronics factories through arrangements between the factories and the schools that the children attend in order to cover alleged tuition debts. The forced labor programs are described as student apprenticeships; however, the children report that they were forced to remain on the job and not allowed to return home. Half of the students' wages are sent directly to the schools, and the children receive little compensation after deductions are made for food and accommodations. In other cases, children are abducted or deceived by recruiters, sent to Guangdong, and sold to employers. Some children are held captive, forced to work long hours for little pay. 

Chinese Translation

China
  Cotton

There are reports that children are forced to pick cotton in China. Reports from an NGO and the U.S. Government indicate that children in the Xinjiang Uighur Autonomous Region and in Gansu province are mobilized through schools and required by provincial regulations to work during the autumn harvest. According to the most recently available estimates, between 40,000 and 1 million students are mobilized annually for the harvest, beginning as early as the third grade. Most children are paid little if at all, after deductions for meals, transportation, and payments to the school. These students are required to pick daily quotas of cotton or pay fines, and performance in the cotton harvest is assessed for the students' promotion to higher grade levels. 

Chinese Translation

China
  Toys

There are reports that children, mostly ages 13-16, are forced to produce toys in China. The most recently available data from an NGO study indicates that hundreds of children are exploited in this manner. Reports indicate children from Sichuan, Guangxi, and other provinces are sent to work primarily in Guangdong to make toys. Some of these children are trafficked after being recruited through deceptive promises, and others are forced to work by teachers through work-study programs. Children of the Yi ethnic minority in Liangshan prefecture of Sichuan are particularly vulnerable. The children report being forced to work long hours under threat of financial penalty and being fined for any mistakes in their work. Some children state that teachers withhold wages for “tuition” and management fees. In addition, employers withhold wages for months to prevent children from leaving. 

Chinese Translation

China
  Bricks

There are reports that children, ages 8-17, are forced to produce bricks in China, with concentrations in the Shanxi and Henan provinces. Victims are from provinces across China; some children are abducted or trafficked through coercion and sold to work in brick kilns. Information from media sources and a research study indicate that the children are forced to work without pay under threat of physical violence, held against their will, watched by guards, and denied sufficient food. 

Chinese Translation

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Public Comments and Submissions

Each revision to the List is published first as an Initial Determination for public comment. The Departments of Labor, State and Homeland Security consider all public comments before publishing a Final Determination to revise the List. ILAB also accepts public submissions about the List on an ongoing basis, and reviews them as they are received. To submit information, please send an email to eo13126@dol.gov; fax to 202-693-4830; or mail to ILAB, U.S. Department of Labor, c/o OCFT Research and Policy Unit, 200 Constitution Ave NW, S-5317, Washington, DC 20210. View the list of submissions.