India Bans Import of Goods Made Using Forced Labour — Notification 23/2026-27 Explained
Directorate General of Foreign Trade (DGFT) has introduced new provisions allowing imports made with forced labour to be prohibited after an enquiry. On 13 July 2026, it notified a new provision that bans the import of goods made using forced labour — full stop, no qualifiers. The notification is particularly relevant for importers, procurement teams and compliance professionals handling overseas sourcing.
The change comes through Notification No. 23/2026-27, issued under Section 3 read with Section 5 of the Foreign Trade (Development & Regulation) Act, 1992, along with paragraphs 1.02 and 2.01 of the Foreign Trade Policy (FTP) 2023. The amendment allows the government to prohibit imports after an enquiry establishes that forced labour was involved.
If your business imports raw materials or finished goods, this notification could affect your supply chain. The following sections explain the amendments and their implications for importers.
๐ Notification 23/2026-27 — At a Glance
| Detail | Information |
|---|---|
| Notification Number | 23/2026-27 |
| Date of Issue | 13 July 2026 |
| Issuing Authority | DGFT, Department of Commerce, Ministry of Commerce & Industry |
| Legal Basis | Section 3 read with Section 5, FTDR Act 1992; Paras 1.02 and 2.01 of FTP 2023 |
| New Provisions Inserted | Para 2.20B (prohibition) and Para 11.64 (definition of "Forced Labour") |
| Effective From | 30 days after publication in the Official Gazette |
| Definition Basis | ILO Forced Labour Convention, 1930 (No. 29) |
| Enquiry Authority | Director General of Foreign Trade (DGFT) |
| Enquiry Procedure | As prescribed in the Handbook of Procedures, 2023 |
๐งพ What Exactly Was Inserted Into the FTP
The notification makes two specific additions to the Foreign Trade Policy, 2023 — one operative provision and one definition. The amendments serve two separate purposes:
| Provision | What It Does | Practical Meaning |
|---|---|---|
| Para 2.20B | Prohibits import of goods produced or manufactured, wholly or in part, using labour rights violations. Empowers the Central Government to specify — by future notification — exactly which goods fall under this ban, based on enquiry findings. | The ban isn't limited to a fixed list right now — the government can add specific goods to the prohibited list later, based on investigations into forced labour in their production. |
| Para 11.64 | Inserted under Chapter 11 (Definitions) of the FTP. Defines "Forced Labour" using the ILO Forced Labour Convention, 1930 (No. 29) — work or service exacted from a person under threat of penalty, without that person offering themselves voluntarily. | This gives DGFT a legally precise, internationally recognised standard to work from when investigating whether a product's supply chain involved forced labour. |
๐ How the Enquiry Process Is Meant to Work
The notification doesn't ban a specific product list on day one. Instead, it sets up a mechanism: the Director General of Foreign Trade can open an enquiry into whether a particular good is being produced using prohibited labour practices, using whatever findings or material it considers appropriate, following the procedure laid out in the Handbook of Procedures, 2023. Once that enquiry is complete, the Central Government can then notify that specific good as prohibited for import.
In practice, the government isn't banning every imported product overnight. Instead, it now has a legal process to investigate goods suspected of being made with forced labour.
For example, consider an Indian company importing cotton textiles from an overseas supplier. For example, if evidence gathered during a DGFT enquiry indicates that imported cotton was produced using forced labour, the government may notify those goods for prohibition. If DGFT receives credible information — say, from an international labour body or an investigative report — suggesting forced labour was used at some stage of that product's manufacturing, it can now open a formal enquiry under Para 2.20B. If the enquiry finds evidence, the government can notify that specific product category as prohibited for import, and any company still importing it after that notification would be in violation of the FTP.
๐ Why the amendment is commercially significant
The approach aligns with measures already adopted in several major trading economies. Countries like the US already enforce forced-labour import bans aggressively — the US Customs and Border Protection's Withhold Release Orders under the Uyghur Forced Labor Prevention Act have blocked billions of dollars of goods at the border in recent years. The EU has similar forced-labour due diligence rules coming into force around the same period. By writing its own forced-labour prohibition into the FTP, India is aligning itself with a global trend where trade policy and labour rights enforcement are increasingly linked.
The amendment creates both compliance obligations and commercial opportunities. On one hand, it adds a new compliance layer to check before finalising import contracts. On the other, it positions India's trade policy in line with the standards many of its own export buyers — in the US and EU — already demand from Indian exporters. It's not hard to see this as India tightening its own import standards to match the scrutiny its exporters already face abroad.
Although the notification doesn't immediately prohibit every imported product, businesses sourcing from high-risk regions should begin reviewing supplier documentation now. Companies with strong due diligence systems are likely to face fewer compliance issues once enforcement begins.
✅ Implications for Importers — Practical Takeaways
- ๐ฆ Importers of raw materials and intermediates — Review your overseas supplier base, especially in sectors globally flagged for forced labour risk (cotton, seafood, electronics components, palm oil). Start documenting supplier labour practices now, before any product-specific notification lands.
- ๐ญ Manufacturers sourcing internationally — If your supply chain runs through regions or industries with known prohibited labour practices concerns, build supplier audits into your procurement process ahead of the 30-day effective window.
- ⚖️ Compliance and legal teams — Set up a tracking process for future DGFT notifications under Para 2.20B — since the actual banned-goods list will come through separate notifications, not this one.
- ๐ Export-focused businesses — If you already comply with forced-labour due diligence for US or EU buyers, much of that documentation may now double up as protection against India's own import scrutiny too.
- ๐ Trade consultants and CHAs — Familiarise yourself with the DGFT enquiry procedure under the Handbook of Procedures, 2023, since this will likely become a recurring compliance checkpoint for clients importing from higher-risk regions.
This notification is really the legal foundation, not the final word. The real impact will show up over the coming months as DGFT starts naming specific goods and, likely, specific supply chains under enquiry. Businesses with documented supplier due-diligence procedures are likely to face fewer compliance challenges if product-specific prohibitions are introduced.
Follow Exim News 24 for daily updates on India's trade policy, DGFT notifications, and compliance requirements for importers and exporters.
✅Frequently Asked Questions (FAQ)
Q1. Does this notification immediately ban all imported goods?๐ Also Read
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Disclaimer: All information in this post is sourced from DGFT Notification No. 23/2026-27, dated 13 July 2026, issued by the Ministry of Commerce & Industry, Government of India. This notification inserts Para 2.20B and Para 11.64 into the Foreign Trade Policy, 2023, and comes into effect 30 days after publication in the Official Gazette. Importers should consult the official Gazette notification and the Handbook of Procedures, 2023, and seek professional advice before making sourcing or compliance decisions. This post is for informational and awareness purposes only.
