Forced labor: What products could be blocked by Customs following Donald Trump’s sanctions?

A new chapter in trade and labor regulation has opened in the Caribbean following the Trump administration’s recent decision to implement a 12.5% additional tariff on imports from the Dominican Republic. The U.S. move was rooted in claims that the Dominican government has failed to take sufficient action to address widespread forced labor in the country’s key sugarcane sector. In direct response, Dominican authorities have rolled out a formal regulatory framework to bar all goods produced wholly or partially through forced labor from entering its national market.

The new policy is codified in Decree 502-26, signed and publicly released on the evening of Thursday, July 23. The legislation grants broad enforcement authority to the Dominican Republic’s General Directorate of Customs (DGA), tasking the agency with implementing the import ban and conducting investigations into suspected violations.

While the decree does not outline a pre-approved list of banned goods, U.S. Department of Labor (USDOL) findings have long flagged sugarcane and sugar-derived products from the Dominican Republic as high-risk for forced labor inputs. USDOL first added Dominican sugarcane produced with forced labor to its List of Goods Produced with Child Labor or Forced Labor back in 2009. Multiple subsequent reports have confirmed that exploitative conditions remain pervasive across the country’s entire sugarcane sector, impacting plantations operated by private corporations, state-owned entities, and small independent producers alike.

According to USDOL’s public analysis, the most vulnerable workers in Dominican sugarcane production are people of Haitian origin or descent, who are often subjected to living and working conditions that meet international definitions of forced labor. These sugarcane inputs are then used to manufacture a wide range of goods for export and domestic consumption: raw sugar, refined sugar, molasses, rum, bagasse, and furfural are the primary Dominican exports at the center of the debate. Beyond these core products, research indicates that forced labor-derived sugarcane inputs could also end up in beverages, confectionery, baked goods, processed foods, animal feed, paper, pulp, construction materials, biofuels, industrial chemicals, and pharmaceutical products.

Trade data illustrates the deep economic ties between the two countries: the U.S. imports nearly all Dominican raw sugar exports and the majority of its molasses exports, purchasing more than $131 million worth of raw Dominican sugar in 2023 alone. The European Union, by contrast, imports 100% of Dominican furfural production.

Under the terms of the new Dominican decree, DGA officials have the power to enact provisional protective measures while formal investigations are ongoing. These interim actions include suspending customs clearance for suspicious shipments, temporarily detaining suspected goods, and implementing any other steps necessary to stop high-risk products from entering the domestic market before a final ruling is issued. These measures apply even to shipments that have already departed for the Dominican Republic, are currently in Dominican ports, or are undergoing pre-import customs processing as of the decree’s entry into force.

The legislation also mandates the creation of a centralized national administrative registry of products banned from import. DGA will maintain an up-to-date record of all goods that have been formally barred via final administrative decision, with entries including detailed supply chain information: producer and manufacturer identity, supplier details, production facility locations, country/region of origin, and other data to help authorities trace the origin of suspicious shipments and enforce the ban. The registry will be updated regularly to reflect new rulings, modifications or revocations of existing bans, and any other changes that impact its content. The framework explicitly notes that only products formally added to the registry are banned, with no blanket restrictions applied to unconfirmed goods or suppliers.

To clarify the scope of the policy, the decree aligns its definition of forced labor with standards set by the International Labour Organization (ILO). The ILO defines forced labor as any work performed involuntarily, under the threat of some form of punishment or coercion. Common coercive tactics include physical violence and intimidation, withholding of identity documents to trap workers, and manipulated debt arrangements that leave workers unable to leave their positions. Under the 1930 ILO Forced Labor Convention, three core elements must be present to classify work as forced labor: the performance of work or service in any economic sector (including the informal economy), a threat of punishment for non-compliance or escape, and a lack of genuine voluntariness on the part of the worker. The ILO emphasizes that forced labor can impact adults and children across a wide range of sectors, but also clarifies that poor working conditions alone do not automatically meet the definition of forced labor.

The Dominican Republic’s new import ban comes in direct response to the Trump administration’s updated global trade tariffs, which were announced by the Office of the United States Trade Representative (USTR) led by Jamieson Greer. The new tariff schedule grew out of Section 301 trade investigations launched by USTR in March 2025, which sought to determine whether other countries’ policies on forced labor-made goods harm U.S. workers and businesses. The 12.5% tariff on the Dominican Republic replaces a temporary 10% global tariff implemented by the Trump administration earlier this year, which expired on July 25 2025. This new round of tariffs marks the next phase of the trade war the Trump administration has driven since April 2025.

Under the new schedule, the U.S. imposes a 10% additional tariff on imports from 17 global economies and a 12.5% tariff on others, with variable rates for some partners depending on product type. In Latin America, Mexico, Guatemala, Honduras, and El Salvador face the 10% rate, while Costa Rica, Panama, and the Dominican Republic fall into the 12.5% category. All 27 member states of the European Union face a combined 10% tariff. Other major affected economies include India, Japan, South Korea, Taiwan, Switzerland, Canada, and the United Kingdom, with variable rates based on product and origin. Notably, China, which has long been the target of U.S. trade tariffs, does not appear on the new list, facing separate, higher specific tariffs instead.