With President-elect Trump’s official nomination of Senator Marco Rubio for Secretary of State, questions arise about the potential impact on importers—particularly e-commerce giants like Shein and Temu, which rely heavily on Chinese imports—given Rubio’s strong stance on China’s trade practices, including alleged forced labour. Rubio has gained bipartisan recognition for his tough approach to China. Known for his vocal opposition to Chinese trade practices and alleged human rights violations, Rubio’s appointment could signal a significant shift in US foreign policy and trade enforcement.

A track record of toughness on China

Rubio has consistently advocated for aggressive measures against Chinese trade abuses, including forced labour allegations. As a lead sponsor of the Uyghur Forced Labor Prevention Act (UFLPA), Rubio has spearheaded efforts to prohibit imports from China’s Xinjiang region unless businesses can prove their supply chains are free from forced labour. This legislation has forced many companies to more closely examine their supply chains and sourcing practices and has heightened scrutiny of ecommerce giants like Shein and Temu, which have faced allegations of benefiting from forced labour, though they have both denied any links to forced labour. Shein has also faced allegations of human rights violations and other abuses in the UK.

Critics and supporters alike agree that Rubio’s approach reflects a growing, cross-party consensus for stricter trade enforcement. His past efforts to tighten the de minimis exemption—a provision allowing low-value shipments to enter the US without tariffs or extensive inspections—underscore his commitment to closing loopholes that potentially enable forced labour-tainted goods to enter US markets.

Impacts on businesses

If confirmed, Rubio’s leadership at the State Department could bring heightened enforcement of trade laws and increased pressure on companies to ensure ethical supply chains. Businesses reliant on Chinese imports, particularly ecommerce platforms, may face stricter regulations and intensified scrutiny. Of course, Rubio won’t be the top decision maker on the UFLPA: that job would fall to Homeland Security, but the State Department does form part of an interagency task force on forced labour. The department has also, in the past, attempted to influence allies such as the EU and UK to match US efforts. 

The prioritisation of these efforts by Rubio and others in Trump’s cabinet picks who have taken a hawkish stance toward China, along with increasingly tighter regulations aimed at fighting forced labour in the UK and EU, is a wake up call for businesses to take proactive measures to mitigate risks and ensure compliance, wherever they are located.

Modern slavery legislation in the UK and the EU:

Under the Modern Slavery Act 2015, businesses across the UK have had to adjust to ensure they comply with the Act. This means large corporations such as ASOS have had to re-think the way they monitor and audit their suppliers. Companies with an annual turnover of over £36 million must produce a slavery and human trafficking statement. The Labour government has committed to embedding modern slavery protections and tackling human rights and labour abuses in both public and private supply chains with due diligence rules. They will mandate the use of human rights protection clauses to tackle modern slavery in supply chains.

In the EU, the Corporate Sustainability Reporting Directive (CSRD) requires all large and listed companies to publish regular reports on the social and environmental risks they face, and on how their activities impact people and the environment. It aims to help investors, consumers, policymakers and other stakeholders evaluate non-financial performance and encourage a more responsible approach to business.

It also impacts non-EU companies, called third-country companies, that have substantial activity in the EU. Businesses need to prepare now as successful reporting will require a holistic approach that involves the entire organisation.

Knowing what to look for in supply chains will help your procurement team identify potential red flags within your supply chain.

VinciWorks has put together a list of six key questions to ask suppliers that can help identify potential modern slavery risks in your supply chain:

Six questions to ask your suppliers

1. Does the factory employ migrant workers? Migrant workers are often at higher risk of exploitation. Understanding their working conditions is crucial.
2. Have there been reported cases of abuse in the region where the supplier operates? Research the region for known human rights abuses.
3. Have there been reported cases of abuse in the industry your company operates in? Industries such as clothing, chocolate, and coal are considered high-risk for forced labour.
4. Are copies of the workers’ contracts readily available? Transparent documentation is a key indicator of ethical labour practices.
5. Do your Key Performance Indicators (KPIs) inadvertently encourage exploitative practices? For example, very low-cost clothing targets may pressure suppliers to cut corners on wages and working conditions.
6. During surprise visits, are children seen in or around the factory? Child labour is a significant red flag for non-compliance.

To view specific points for procurement staff to look out for while carrying audits, download a free supplier audit checklist.

Additionally, identifying potential risks is an ongoing process and it’s important to be able to spot the signs of modern slavery. Here are six common red flags to watch out for in the supply chain:

Six red flags to watch for in the supply chain

1. Signs of Restricted Freedom Workers’ documents being held “for safekeeping” or forced residency on factory premises may indicate coercion.
2. Behavioral Signs Workers who appear frightened, malnourished, or avoid direct communication may be victims of modern slavery.
3. Poor Working Conditions Lack of training, excessive working hours, and unsafe environments are clear indicators of exploitation.
4. Living Conditions Workers without home addresses, living in overcrowded or unsanitary conditions, or lacking house keys should raise concerns.
5. Financial Control Debt bondage—where workers owe their employer for travel, food, or housing—is a common form of modern slavery.
6. Physical Signs of Abuse Physical injuries, malnutrition, or signs of drug addiction are serious indicators of abuse.

By asking the right questions and staying vigilant for red flags, businesses can better navigate the complexities of global supply chains while ensuring compliance with ethical and legal standards. As trade policies continue to evolve under leaders like Marco Rubio, proactive compliance measures will be more critical than ever.

VinciWorks offers comprehensive staff training on modern slavery, which helps companies avoid being connected to activity that violates regulations. In addition, we provide automated workflow solutions for supplier onboarding, Modern Slavery Act reporting, and more.