Manifest Modernization Act: Enhancing visibility into forced labour risks in U.S. supply chains

Monitoring China, United States

Public customs data have been critical in tracing products made with forced labour – from Uyghur camp‑made wigs and Vietnamese debt‑bonded bicycles to palm oil produced under conditions of modern slavery – enabling enforcement of the Tariff Act of 1930, CAATSA and the UFLPA【514992160624532†L13-L39】. However, due to a legislative error in the 1990s, only ocean vessel manifests are publicly available; manifests for air, truck and rail shipments – covering more than 60 % of U.S. imports – remain hidden, creating a blind spot that undermines forced‑labour enforcement【514992160624532†L115-L123】. The Manifest Modernization Act (MMA, S.1259), reintroduced in 2025 by U.S. senators, would require public disclosure of manifest data for all modes of transport【514992160624532†L150-L185】. The authors argue that shipments from Xinjiang may enter the United States via air to avoid detection, and small e‑commerce packages also exploit this loophole【514992160624532†L201-L237】. Expanded transparency would not impose new reporting burdens – the bill simply extends existing ocean‑manifest disclosures – and companies could still request confidentiality where commercially justified【514992160624532†L270-L277】. Public access to manifests would improve cross‑border enforcement under the USMCA, discourage transshipment through Canada and Mexico, and prompt other countries to adopt similar transparency measures【514992160624532†L240-L331】. Ultimately, the commentary concludes that the MMA would close a critical loophole, bolster global trade security and enhance the effectiveness of the UFLPA and other forced‑labour laws【514992160624532†L301-L331】.

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