Published: 15 Jul 2026
DGFT Bans Import of Goods Made Using Forced Labour, Inserting New Para 2.20B and Para 11.64 in FTP 2023
REGULATORY UPDATE | S.O. NOTIFICATION NO. 22/2026-27, DATED 3 JULY 2026 | EFFECTIVE 30 DAYS FROM GAZETTE PUBLICATION
REGULATORY INTELLIGENCE
The Directorate General of Foreign Trade (DGFT), under the Ministry of Commerce & Industry, has amended the Foreign Trade Policy (FTP) 2023 to prohibit the import of goods produced or manufactured using forced labour. The amendment inserts a new Para 2.20B establishing the prohibition and enquiry mechanism, along with a new Para 11.64 defining “Forced Labour” in Chapter 11 of the FTP.
The amendment was notified via Notification No. 22/2026-27, dated 3 July 2026, and comes into force after the expiry of 30 days from the date of its publication in the Official Gazette. Both provisions are final and awaiting the lapse of this notice period before taking effect.
THE AMENDMENTS
What Has Changed
DGFT has inserted two new provisions into the FTP, 2023 simultaneously:
- Para 2.20B — establishes a prohibition on the import of goods produced or manufactured, wholly or in part, through forced labour, and empowers the Central Government to notify specific goods covered by the prohibition.
- Para 11.64 — inserts a formal definition of “Forced Labour” under Chapter 11 (Definitions) of the FTP, aligned with the ILO Forced Labour Convention, 1930 (No. 29).
The table below summarises the position before and after this notification.
| Parameter | Before Amendment | After Amendment |
|---|---|---|
| Prohibition on forced-labour goods | Not specifically addressed in FTP 2023 | Explicit prohibition under new Para 2.20B |
| Definition of “Forced Labour” | Not defined anywhere in the FTP | Defined under new Para 11.64 (ILO Convention No. 29 basis) |
| Enquiry mechanism for forced-labour claims | No dedicated FTP-linked procedure | DGFT enquiry per Handbook of Procedures, 2023 |
| Effective date | — | 30 days after Gazette publication |
PARA 2.20B — PROHIBITION ESTABLISHED
Under the newly inserted Para 2.20B, the import of goods produced or manufactured using forced labour — wholly or in part — is prohibited. The Central Government retains discretion to specify, by future notification, exactly which goods fall within this prohibition, based on the findings of an enquiry or other material it considers appropriate.
The provision also establishes that enquiries into the use of forced labour in the production of specific goods will be conducted by the DGFT, following a procedure to be prescribed in the Handbook of Procedures, 2023. This is a wholly new compliance mechanism within the FTP framework.
PARA 11.64 — DEFINITION OF FORCED LABOUR
“Forced Labour” is now formally defined as all work or service exacted from any person under the menace of any penalty, and for which that person has not offered themselves voluntarily — a definition drawn directly from the ILO Forced Labour Convention, 1930 (No. 29). Previously, the FTP contained no defined term addressing forced labour, leaving the concept without a legal anchor within Indian trade policy.
WHAT IT MEANS FOR IMPORTERS
For Importers in Labour-Risk Sectors
Importers sourcing from sectors internationally flagged for forced-labour risk — such as textiles, seafood, mining, and electronics components — should begin reviewing supply-chain documentation now. While no goods are prohibited yet, subsequent goods-specific notifications under Para 2.20B could affect ongoing import contracts with limited lead time.
For Compliance and Trade Teams
Compliance teams should track the Handbook of Procedures, 2023 for the enquiry procedure once it is published, and should build supplier due-diligence processes capable of demonstrating labour conditions at the point of manufacture, not merely at the point of shipment.
For Multi-Tier Supply Chains
Businesses with complex, multi-tier sourcing structures — where labour conditions at sub-supplier level are difficult to verify — face the greatest exposure. Traceability gaps that were previously a reputational risk now carry a direct import-eligibility risk under the FTP.
KEY INSIGHT
The insertion of Para 2.20B does not itself ban any specific product — it creates the legal architecture for future goods-specific prohibitions. The real compliance trigger will be subsequent notifications naming affected goods, which importers in labour-risk sectors should track closely. Businesses that wait for a product-specific notification before building supply-chain traceability will have far less lead time to respond than those who begin due diligence now, during this 30-day window before the provision takes effect.
BUSINESS IMPACT
- Importers should map supply chains now to identify forced-labour exposure risk ahead of any goods-specific prohibition.
- Documentation of labour practices at manufacturing and sourcing level will become material to import clearance.
- Trade compliance teams should monitor future DGFT notifications issued under Para 2.20B.
- Businesses should track the Handbook of Procedures, 2023 for the enquiry mechanism once published.
- Sectors with known forced-labour risk exposure should prioritise early legal and compliance review.
- The 30-day window before the provision takes effect should be used for internal readiness, not deferred.
CONCLUSION
This notification establishes a formal legal basis within the FTP 2023 for prohibiting imports of goods made using forced labour, backed by a defined term and a dedicated enquiry mechanism. With the provisions taking effect 30 days after Gazette publication, businesses importing goods with potential forced-labour exposure should begin reviewing supply chains and compliance documentation now, and should track subsequent DGFT notifications specifying affected goods.
HOW OMEGA QMS CAN HELP
At Omega QMS, we help businesses navigate India’s evolving regulatory framework, including BIS certification, customs regulations, import-export procedures, QCO compliance, and foreign trade policy compliance. If your business requires assistance with supply-chain due diligence or import compliance under the amended FTP 2023, our experts can help ensure timely and seamless compliance.
REFERENCE
Directorate General of Foreign Trade, Ministry of Commerce & Industry, Department of Commerce, Government of India — Notification No. 22/2026-27, “Prohibition on Import of Goods Produced Using Forced Labour – Insertion of Para 2.20B and Para 11.64 in the Foreign Trade Policy (FTP) 2023,” dated 3 July 2026. (To be published in the Gazette of India, Extraordinary, Part-II, Section-3, Sub-Section (ii).)
This article is for informational purposes only and does not constitute legal advice.