Commerce Department Must Train Staff and Advise U.S. Businesses on Avoiding Forced Labor Supply Chains

The Combating CCP Labor Abuses Act of 2025 mandates two key actions for the Department of Commerce aimed at cutting off U.S. business ties to human rights abuses in China. First, it requires the Secretary of Commerce to implement new training for employees who counsel U.S. businesses on interstate commerce and foreign investment. This training must focus specifically on raising awareness of human rights abuses, especially forced labor targeting Uyghurs and other minorities in the Xinjiang Uyghur Autonomous Region (XUAR), ensuring Commerce staff are equipped to discuss these risks with companies (Sec. 2).

Second, and perhaps more impactful for the average business, the bill requires the Commerce Department to issue advisory guidance to U.S. companies doing business overseas (Sec. 3). This guidance is designed to help businesses spot the warning signs—the 'red flags'—that indicate a potential partner is controlled by a government known for human rights violations, specifically the Chinese government and its use of forced labor in XUAR. The goal is to give companies the tools to identify and avoid these risky entities and understand the potential fallout—reputational damage, economic losses, and legal headaches—if they don't.

The Fine Print: What it Means for Your Supply Chain

If you run a small manufacturing company or a retail business that sources components or finished goods overseas, this guidance is a big deal. While the advice is strictly advisory—meaning the government can’t force you to change suppliers—it’s essentially the Commerce Department handing you a roadmap for de-risking your supply chain. For example, if you’re considering a new supplier for textiles, the guidance might detail specific regional or ownership structures that signal forced labor risk, allowing you to choose a safer alternative before a major compliance issue hits the news.

Training the Trainers

Section 2 addresses the government side, ensuring that the Commerce employees who advise U.S. companies are up-to-speed on these complex international issues. Think of it as specialized professional development. By mandating that the training be woven into existing programs, the bill aims for efficiency, but it also gives the Secretary of Commerce discretion over which employees get the training and when it’s updated. This flexibility could lead to inconsistent application if not managed rigorously, as the quality of advice businesses receive depends entirely on the quality of the training given to the government staff.

The Advisory Nature: A Gentle Nudge, Not a Mandate

It’s crucial to remember that the guidance issued under Section 3 is explicitly advisory. This means U.S. businesses retain the final decision on their partners. For companies that have already invested heavily in supply chains linked to the XUAR region, this bill won't immediately force them to divest, but it significantly raises the stakes. The government is essentially saying, “We’ve told you the risks and shown you the warning signs; if you proceed, you do so knowing the potential legal and reputational consequences.” The intent is clearly to discourage U.S. complicity in forced labor by making the risks transparent and easy to understand for busy executives and compliance officers.