As the U.S. government continues to crack down on forced labor linked to Xinjiang, China, experts are providing insights on how companies can better design their due diligence programs and effectively assess risks within their supply chains.
During a Nov. 19 webinar—co-hosted by Kharon and Trustrace—focused on addressing forced labor risks, founder of ESG consultancy Green-ish.co and former apparel executive, Liz Hershfield, emphasized that companies should first prioritize the development of a clear process on how they plan to assess and mitigate forced labor risks with their suppliers.
She noted that the process should be supported with documentation and technology that can make it easier and more efficient.
Another key element is for companies to set clear expectations and requirements with their suppliers regarding forced labor risks.
“A good way to approach it is thinking about the impact of your business and who you want to start with, who are your biggest suppliers, and who are those folks that they work with,” Hershfield said.
“Assessing risk is obviously really critical in understanding where you have exposure in your supply chain,” she said, noting that there are different levels of risk and how companies address them will depend on their industry and suppliers.
Hershfield also emphasized the importance of regularly mapping supply chains and understanding who companies are doing business with. She recommended that businesses conduct risk assessments quarterly or biannually.
During a Nov. 19 webinar—co-hosted by Kharon and Trustrace—focused on addressing forced labor risks, founder of ESG consultancy Green-ish.co and former apparel executive, Liz Hershfield, emphasized that companies should first prioritize the development of a clear process on how they plan to assess and mitigate forced labor risks with their suppliers.
She noted that the process should be supported with documentation and technology that can make it easier and more efficient.
Another key element is for companies to set clear expectations and requirements with their suppliers regarding forced labor risks.
“A good way to approach it is thinking about the impact of your business and who you want to start with, who are your biggest suppliers, and who are those folks that they work with,” Hershfield said.
“Assessing risk is obviously really critical in understanding where you have exposure in your supply chain,” she said, noting that there are different levels of risk and how companies address them will depend on their industry and suppliers.
Hershfield also emphasized the importance of regularly mapping supply chains and understanding who companies are doing business with. She recommended that businesses conduct risk assessments quarterly or biannually.
“It's not just a one and done thing,” she said. “As suppliers continue to do business with new or different partners, the risk will always be inherent.”
Once companies identify a risk, Hershfield said they should then determine whether to continue working with the same suppliers—providing training on how to identify and mitigate future risks—or to sever ties if that’s the more appropriate route.
Since the implementation of the Uyghur Forced Labor Prevention Act (UFLPA) in 2022, the U.S. Customs and Border Protection (CBP) has detained and inspected more than 10,000 shipments valued at over $3.6 billion. So far, 107 entities have been added to the UFLPA Entity List.
Once companies identify a risk, Hershfield said they should then determine whether to continue working with the same suppliers—providing training on how to identify and mitigate future risks—or to sever ties if that’s the more appropriate route.
Since the implementation of the Uyghur Forced Labor Prevention Act (UFLPA) in 2022, the U.S. Customs and Border Protection (CBP) has detained and inspected more than 10,000 shipments valued at over $3.6 billion. So far, 107 entities have been added to the UFLPA Entity List.

Listen to expert panelists from Kharon, TrusTrace, and Green-ish discuss real-life examples of UFLPA risk from Kharon’s research. Panelists share best practices and offer practical advice for how importers can effectively respond to identified risks in their supply chain. Click to watch the webinar on-demand.