Leading the Fight Against State-Imposed Forced Labor in the Cotton Fields of Turkmenistan

• Enforce national laws that prohibit the use of forced and child labour in alignment with ILO conventions.

• Issue public, high-level policy statements condemning forced labour and explicitly prohibit the use of coercion to mobilize anyone to work, or to hire pickers, pay for replacement pickers or otherwise finance the picking of cotton - such as via a presidential decree or instruction.

• Take action to hold officials accountable for mobilizing and extorting citizens and provide remedy for those affected.

• Fully cooperate with and implement recommendations from UN treaty bodies, UN Special Procedures, and ILO Supervisory Mechanisms, including recent recommendations from the ILO Committee on the Application of Standards (CAS), the ILO Committee of Experts on the Application of Conventions and Recommendations, the UN Committee on the Rights of the Child, and the UN Committee on the Elimination of Discrimination against Women.

• Ensure that independent labor monitors, independent trade unions, journalists, and human rights defenders can operate freely to document and report labor conditions without fear of reprisal.

The government of Turkmenistan should protect civic freedoms and ensure that forced labor reforms involve the broader enabling of fundamental rights such as freedom of expression and freedom of association. In this pursuit and beyond, it should meaningfully involve international independent social partners in the reform process. This is in line with the 2024 Conclusions of the ILO CAS, which called on the government of Turkmenistan to engage with independent social partners as a critical element to ensuring the full application of the Convention 105 on the Abolition of Forced Labour.

The government should also publicly report on concrete measures taken and tangible results achieved to eliminate state-imposed forced labour and child labour, including on the specific goals committed to in the framework of the roadmap of cooperation activities between the ILO and the Government of Turkmenistan for 2024-2025.

Foreign governments should increase pressure on the Turkmen government to eliminate forced labor by employing both a human and labor rights framework in accordance with UN and ILO conventions and standards, and a human rights due diligence framework, consistent with national laws governing human rights due diligence, supply chains, and imports, which require global companies to not source products made with forced labor.

Governments should reinforce with the Turkmen government, in bilateral and multilateral human rights dialogues, that forced labor must be eliminated. They should support labor and human rights defenders in Turkmenistan, including by raising concerns about ill-treatment against them, meeting with labor and human rights defenders, and publicly expressing concerns when people are harassed for conducting human rights work.

Governments should also use their “voice and vote” at the World Bank, Asian Development Bank, European Bank for Reconstruction and Development, and other international finance institutions to prevent any investment that directly or indirectly contributes to Turkmenistan’s forced labor cotton production system. Domestically, governments should introduce and enforce import controls on products made (in whole or in part) or transported with forced labour, which would allow for the prohibition of products containing Turkmen cotton. Governments should also enact mandatory human rights and environmental due diligence legislation, which require all forms of business enterprises to conduct human rights due diligence in their value chains, and map and disclose their supply chains. Crucially, laws should hold companies accountable for preventing human rights abuses in their value chains.

Specifically:

• The European Union, in negotiations on the Omnibus CS3D text, should retain the Articles of the CS3D that included the need to terminate business relationships where there is no reasonable expectation that efforts will succeed, such as in situations of state-imposed forced labor.

• The European Union, in the development of guidelines and reviews of the Forced Labour Regulation, should allow for guidelines on ending and remediating forced labor to recognise the need for full disengagement from state-imposed forced labor, for information from civil society reports to be included as a source of information in the database, and for future amendments to enable regional/industry-wide bans in cases of state-imposed forced labor.

• The US Customs and Border Protection Agency (CBP) should detain all shipments of goods containing cotton products from Turkmenistan and publish the list of detentions made and the value of the shipments detained under the WRO. It should also develop a strategy to identify and review shipments of cotton products from suppliers in third countries — including but not limited to Türkiye, Pakistan, Poland, and Italy — that import cotton and semi-finished cotton goods from Turkmenistan. The onus should be on importers to show that they have no exposure to Turkmen cotton.

• CBP should work together with the office of the US Trade Representative, Canada Border Services Agency, and Employment and Social Development Canada to encourage enforcement of the labor provisions of the USCMA and ensure that products subject to the WRO over Turkmen forced labor cotton allegations are not permitted to enter Canada.

• The Canada Border Services Agency should publicly recognize cotton goods originating in Turkmenistan or containing Turkmen cotton as goods produced with state-imposed forced labor and introduce a country wide ban against cotton from Turkmenistan, similar to the US WRO. It should also publish the list of detentions made and the value of the shipments detained under the Customs Tariff item No. 9897.00.00; and work together with US and Mexico counterparts to ensure enforcement of the USMCA forced labor provisions, and that products subject to the US WRO on Turkmen forced labor cotton are prohibited from entering Canada.

The ILO should meaningfully consult with independent international social partners, such as the ITUC and the IUF, in all stages of its monitoring work and roadmap development and implementation in Turkmenistan, including in the process of negotiating a new Roadmap for 2026 onwards.

In addition, recognizing the severe restrictions on independent organizations inside of Turkmenistan, the ILO should regularly consult with the Cotton Campaign and its independent Turkmen civil society partner organizations.

In its discussions with the Turkmen government, the ILO should raise concerns about the safety and access of independent monitors publicly and at the highest levels, and make clear that their ability to work unimpeded is a vital sign of the government’s good faith and a requirement for ILO assistance. It should also make clear that ending state-imposed forced labor in Turkmenistan requires a broader enabling of all the Fundamental Rights at Work, including freedom of association and collective bargaining, and that other civil and political rights such as freedom of expression are critical to addressing root causes of forced labor.

• Prohibit the use of cotton from Turkmenistan in their products and sign the Turkmen Cotton Pledge to demonstrate their public commitment to eliminate any Turkmen cotton from their products as long as Turkmen cotton is produced with state-orchestrated forced labor.

• Immediately terminate all direct sourcing relationships with Turkmen suppliers, and map their supply chains to the raw materials level to ensure their products are free from cotton originating in Turkmenistan. This requires going beyond existing references to “zero tolerance of forced labor” or other similar language in supplier requirements and proactively engaging with direct suppliers, as well as the spinning and fabric mills in their supply chains.

• Urge companies that use cotton to sign the Turkmen Cotton Pledge and publicly commit to not using Turkmen cotton in their products.

• Urge companies to address current or potential links to the forced labor system of cotton production in Turkmenistan in the companies’ operations and supply chains.

• Cease investments in companies that refuse to discontinue using cotton from Turkmenistan while it is produced with forced labor.

• Support the advocacy efforts of the Cotton Campaign and its partners, and publicly endorse calls to policy makers and international organizations to take stronger action against forced labor in cotton production in Turkmenistan.