About one in four maritime shipment records uses redacted identities, according to a report by the Wharton School at the University of Pennsylvania, “How Forced Labor Scrutiny Shapes Supply Chain Transparency.” Worse, shipments from high-risk supply chains are more likely to have redacted identities, significantly raising the risk of forced labor being hidden in supply chains, say the report’s co-authors, Shankar Parameshwaran and Sandra Schafhäutle. 

They argue that, while importers may seek redaction of their identities and those of their suppliers for sound business reasons (such as competitive confidentiality), businesses’ ability to redact identities in shipment records creates opacity that can mask or normalize forced labor in the supply chain. 

“Firms do not intentionally source from suppliers that use forced labor,” Schafhäutle says. “But in practice, it is difficult to eliminate all forced labor risks from global supply chains. Supplier audits, for example, can help, but they are not perfect. So, firms may still worry that some risky linkages remain and that, if those linkages become public, they could face reputational, legal, or regulatory costs. Our paper suggests that redaction may be one way firms try to manage that remaining exposure.”

Publicly accessible shipment records are an important tool for tracing potential forced labor exposure across global supply chains, because they can reveal which U.S. importers are connected to particular suppliers, origin regions and products, including those associated with forced labor risks. But, under the U.S. Customs and Border Protection’s (CBP) manifest confidentiality program, importers can request the redaction of their own identities and those of their suppliers from public shipment records. 

The rationale is that disclosure could reveal commercially sensitive sourcing relationships, and expose importers to competitive harm. However, redaction can also make it more difficult for third parties to trace forced labor risks and connect them to U.S. import activity, the report says.

According to Schafhäutle, importers can request redactions on the CBP website in a simple online process that takes about half an hour. “Regulators note that redaction provisions are a necessary component of open data initiatives,” she says. “However, based on our knowledge, there are no processes in place to comprehensively monitor and understand the reasons underlying importers’ redaction requests.” 

Importers who seek those redactions are not required to demonstrate that disclosing their identities or those of their suppliers would reveal competitively sensitive information or otherwise harm their market position, the paper points out. The authors suggest that lawmakers may want to examine whether the redaction process calls for reform.

Further, businesses that actively manage risks in their supplier relationships could position themselves as responsive to stakeholders’ demands for information and risk mitigation.

Up until now, the stakes have been relatively low for companies that turn a blind eye, or favor obfuscation when it comes to forced labor, often several supplier-tiers down the supply chain. The punishment has tended to be a legally mandated business redirect, rather than meaningfully punitive action. For example, in July 2025, an Italian court placed a Louis Vuitton Moët Hennessy company, Loro Piana, under judicial administration after uncovering forced labor in its luxury cashmere supply chain. This was the fifth major fashion brand that Italian courts had placed under supervision for labor exploitation since 2023. The others include Armani, Valentino, Alviero Martini, and Dior, all of which used opaque subcontracting chains that relied on exploitative labor, according to Human Trafficking Search. Penalties were designed to be corrective rather than punitive, such as being forced into court-appointed receivership, being mandated to restructure and enhance third-party supplier monitoring, and terminating contracts with at-risk workshops. Thorough compliance meant these conditions were quickly lifted. 

However, legislation is beginning to bite. Starting on December 14, 2027, no product made with forced labor may be sold in or exported from the EU market. Enforcement includes ensuring offending products are withdrawn from sale, and then recycled, destroyed or rendered inoperable. The specific amounts of financial penalties to be levied are up to individual EU member states, but are likely to be significant. 

In the U.S., goods made with forced labor have been prohibited for nearly a century, under the Tariff Act of 1930, which prohibits the importation of any product mined, produced, or manufactured wholly or in part by forced or convict labor.  

More recently, the Uyghur Forced Labor Prevention Act, which came into effect in June 2022, has shifted the burden of proof squarely onto the importer. Violations can empower CBP to detain, exclude, or seize goods and assess monetary penalties, unless "clear and convincing evidence" shows that no forced labor, situated anywhere in the supply chain, produced any part of the goods. 

Overall, Schafhäutle  says, enforcement has become increasingly stringent in recent years. But there is still an important role to be played by organizations and individuals. “The UFLPA effectively created a blacklist of specific suppliers or localities like Xinjiang in China, with the possibility that the blacklist would grow over time based on continued monitoring by third parties, such as investigative journalists and civil society,” she says.