ExecutiveOrdersEO
EO 13126Executive OrderClinton · D Quiet signal

Executive Order 13126

Prohibition of Acquisition of Products Produced by Forced or Indentured Child Labor

This executive order prohibits U.S. executive agencies from acquiring products made with forced or indentured child labor. It requires the Department of Labor to publish a list of suspect products by country of origin, mandates procurement regulations with contractor certification requirements, and establishes remedies including contract termination and debarment for violators.

Federal Register Open PDF 64 FR 32383

Impact dates

  1. OMB report on actions taken (within 2 years after final rule implementation)

  2. Department of Labor publishes list of products/countries in Federal Register

  3. Federal Acquisition Regulatory Council issues proposed procurement rules

Key directives

  • Department of Labor to publish Federal Register list of products/countries with forced or indentured child labor within 120 days
  • Federal Acquisition Regulatory Council to issue proposed procurement rules within 120 days
  • Contractors must certify good faith efforts and provide access to records
  • Agency heads may terminate contracts, debar/suspend contractors up to 3 years
  • Administrator of General Services to maintain excluded parties list
  • Report to OMB within 2 years after final rule implementation

Who is ordered

Timeline

Immediate

  • EO takes effect upon signing; policy declaration active

Near term (90d)

  • Department of Labor must publish list of products/countries (120 days)
  • Federal Acquisition Regulatory Council must issue proposed procurement rules (120 days)

Long term

  • Report due within 2 years after final rule implementation
  • Ongoing enforcement and debarment actions

Risks & tensions

  • WTO GPA and NAFTA carve-out may limit effectiveness for major trading partners
  • Certification relies on contractor self-reporting with limited verification mechanisms
  • Judicial review waiver (Section 7) may limit accountability; text explicitly denies enforceable rights
  • Definition of 'reasonable basis to believe' for list inclusion is vague and subject to political pressure
  • Micro-purchase threshold exemption leaves gap for small acquisitions
Executive Order 13126: Prohibition of Acquisition of Products Produced by Forced or Indentured Child Labor · Executive Orders