Where requirements and expectations come from
Human rights due diligence began as a voluntary framework, reflected in the UN Guiding Principles on Business and Human Rights and the OECD guidelines, but parts of it now carry legal consequences. US law prohibits importing goods made with forced labor, and US Customs and Border Protection can detain shipments it believes are linked to it. Under the Uyghur Forced Labor Prevention Act, goods tied to the Xinjiang region or to listed entities are presumed to be made with forced labor unless the importer can rebut that presumption with detailed evidence. California, for example, requires certain large retailers and manufacturers to disclose their efforts on supply chain labor issues, and European due diligence rules have been narrowed and delayed by later amendments, so their current reach needs checking for companies selling in Europe. Customers and lenders often add their own requirements through contracts.
Mapping suppliers and keeping evidence
Effective due diligence starts with knowing who your suppliers are beyond the first tier, which is often harder than it sounds. Gather supplier lists, purchase records, certificates of origin, audit reports, and the codes of conduct and contract terms suppliers have accepted. For goods that may face customs scrutiny, traceability documents showing the source of raw materials can matter as much as the finished product's paperwork. Grievance channels for workers, and records of how complaints were handled, show that the process works in practice. A policy that exists on paper but never influences actual purchasing decisions tends to carry little weight with regulators or customers.
Setting priorities in the first review
Our first step is to sort which obligations apply to your company by law, which come from customer contracts, and which are voluntary commitments the company has made publicly. Public statements about supply chains deserve care, because claims that turn out to be inaccurate can lead to consumer protection or securities issues. If a shipment has already been detained, the focus shifts to the customs procedure, its response dates, and the evidence the agency is asking for. For a broader program, we identify the highest-risk products and regions first rather than trying to audit everything at once. The aim is a process the company can repeat, document, and explain.
