On 23 June 2026, the Cabinet acknowledged the result of the United States Section 301 investigation concerning Thailand in relation to the alleged failure to prevent the importation of goods produced with forced labor. The Cabinet also approved the establishment of a committee responsible for setting standards for imported goods at risk of forced labor or forced services.
The committee is expected to design measures and guidelines for addressing imported goods at risk of forced labor, while taking into account Thailand’s international obligations and the WTO Most-Favoured-Nation principle. It is also expected to establish criteria, guidelines and standards for reviewing certification documents, and to propose Watchlist, Blacklist or Risk List designations to the Cabinet.
Once Cabinet-approved recommendations are available, they are to be forwarded to the Department of Foreign Trade for issuance of notifications under Section 5 of the Export and Import of Goods Act B.E. 2522 (1979). This indicates that the eventual controls may operate through import notification, certification, licensing, restriction or other customs-facing procedures rather than through labor law alone.
Figure 1. Import Controls Framework: Thailand is building an import-control path around forced-labor risk.
Legal and Commercial Analysis
The development is important because it reframes forced-labor exposure as a trade and customs compliance issue. Thai businesses have traditionally treated labor-risk compliance as a matter of employment law, social audits, supplier codes of conduct or buyer requirements. A formal import-control mechanism would create a direct regulatory link between labor due diligence and the ability to import goods into Thailand.
For multinational companies, the proposed framework also has cross-border significance. Forced-labor regimes in the United States, the European Union and other markets increasingly require importers to prove supply-chain integrity, product origin and labor-risk controls. Thailand’s response appears intended not only to address the U.S. Section 301 process, but also to protect Thailand’s trade reputation and align import practices with international expectations.
The most immediate legal uncertainty is the scope of goods and documents that will be covered. Until Department of Foreign Trade notifications are issued, companies should avoid assuming that the measure will be limited to one sector. The reference to Watchlists, Blacklists and Risk Lists suggests that the framework could be updated over time and may focus on goods, suppliers, countries, regions, production processes or certification gaps.
Businesses that import raw materials or components into Thailand should therefore prepare a defensible supply-chain file. That file should show product origin, supplier ownership, labor practices, subcontracting arrangements, recruitment practices, audit history, transportation route and any certifications relied upon. Thai importers that supply global buyers should also consider aligning their Thai documentation with U.S. and EU forced-labor due diligence expectations.
| Expected Control Layer | Likely Business Impact |
| Risk lists | Goods, suppliers or jurisdictions may be categorized for enhanced scrutiny. |
| Certification review | Importers may need to retain reliable labor-origin and supply-chain documents. |
| DFT notification | Import procedures may become conditional on future Department of Foreign Trade rules. |
| Customs interface | Documentation gaps could affect clearance, buyer confidence and contractual delivery obligations. |
Practical Client Action Points
✓ Map suppliers, subcontractors and production locations for imported goods and key inputs.
✓ Update supplier contracts to require forced-labor warranties, document cooperation and audit rights.
✓ Create an internal file for origin evidence, labor certifications, audit reports and corrective-action records.
✓ Monitor Department of Foreign Trade notifications issued under the Export and Import of Goods Act.
✓ Coordinate Thai import compliance with overseas buyer requirements, particularly for U.S. and EU-facing supply chains.
Figure 2. Due Diligence and Evidence Files: importers should build the evidence file before rules are issued.
This publication is provided for general informational purposes only and does not constitute legal, regulatory, tax, customs, or professional advice. For further information or advice regarding the potential implications of Thailand’s developing forced-labor import control framework, please contact one of our lawyers at Mahanakorn Partners Group (MPG) at [email protected].