On 2 October 2026, USTR published a joint statement by the trade ministers of the United States, Mexico and Argentina. They committed to stronger measures, information exchange and enforcement cooperation against goods made with forced labor. The statement is a policy commitment; it does not create a new product list, effective date or single customs procedure. Buyers still need an evidence system tied to their products and shipments.
1. Define the destination market and trigger
Record the destination, importer, product, expected entry date and buyer requirement. Markets may use import prohibitions, market bans, corporate due-diligence rules or procurement controls. Ask the importer to confirm the applicable rule and division of responsibility.
2. Lock the entities and production sites
Capture the registered supplier, business identifiers, registered address, actual factory, subcontract sites, payee and exporter. Explain name changes, affiliates and trading-company relationships. Reconcile the result with your supplier-vetting file.
3. Map upstream inputs and processing
Work backward from the finished goods through key materials, components, processing steps, tier-one suppliers and known upstream tiers. Replace labels such as “domestic source” with supplier, origin location, purchase lot and finished-goods lot wherever the risk requires it.
4. Assess labor risk beyond an audit
Screen the sector, location, labor recruiter and employment model. The U.S. Department of Labor's SourcingStrong framework treats risk assessment, codes, training, monitoring, remediation, independent review and reporting as a continuing system. ILO indicators help identify clues; one site audit is only one evidence item.
5. Collect order-level traceability
Link purchase orders, invoices, payments, receipts, material issues, production lots, logistics and export documents under the same order reference. Quantities, dates, entities and locations should reconcile. Missing or unexplained transitions need evidence or escalation.
6. Triangulate declarations with facts
A supplier declaration records responsibility but does not prove the underlying facts. Cross-check it through document sampling, interviews, observations, independent verification or the importer's required process. Record labor recruiters, subcontracting and temporary labor separately.
7. Track gaps, remediation and review triggers
Classify open points as missing documents, further investigation, shipment hold or qualified-adviser review. Reassess when the supplier, upstream source, site, labor recruiter or order structure changes. “No issue found in this review” is a bounded conclusion, not an absolute guarantee.
Copy this evidence-pack index
- Destination / importer / applicable requirement / reviewer: ___.
- Producer / exporter / payee / production sites: ___.
- Key-input and upstream-supplier map: ___.
- Employment model / recruiters / risk screening: ___.
- Order, purchase, payment, lot and logistics reconciliation: ___.
- Declarations, audit, interviews and independent checks: ___.
- Evidence gap / remediation / owner / deadline: ___.
- Change trigger / next review date: ___.
What the three-country statement changes
The ministers support adopting, maintaining and enforcing measures that prohibit the import or sale of goods produced wholly or in part with forced labor, while exchanging information on higher-risk goods, supply chains and enforcement practices. The statement cites an ILO estimate of 28 million people in forced labor in 2021. It signals greater policy coordination; it does not publish a new customs instruction for a particular shipment.
Sources and limits
Verified 3 October 2026. Policy update: USTR's 2 October announcement and the joint statement. System design: U.S. Department of Labor SourcingStrong. Risk clues: ILO indicators. This is an operational evidence framework, not legal advice, a customs decision, a social-audit certification or a guarantee that a supply chain is risk free.
Frequently asked questions
Is a supplier declaration enough?
No. Reconcile it with entities, sites, upstream inputs, payments, logistics and lot records.
Does one factory audit cover upstream risk?
No. Map upstream tiers, labor recruiters, higher-risk inputs and later changes.
Did the joint statement create a new import ban immediately?
No. It records a policy direction but provides no new product list, effective date or customs procedure.
Need this evidence pack inside your sourcing workflow?
Use the Export Toolkit to align supplier and order fields, then contact Chris to discuss an evidence structure. Do not send worker identities, customer data or supply-chain-sensitive records through a public message.