DGFT Import Compliance Update

DGFT Introduces Investigation Procedure for Forced Labour Imports: What Importers Need to Know

Omega QMS Compliance Insights

Omega QMS

India has strengthened its trade compliance framework by introducing a formal procedure for investigating whether imported goods are produced using forced labour.

Through DGFT Public Notice No. 21/2026-27 dated 13 July 2026, the Directorate General of Foreign Trade (DGFT) has inserted Para 2.50A into the Handbook of Procedures (HBP), 2023. The new provision establishes how DGFT will investigate suspected cases of forced-labour imports before recommending any prohibition.

This follows DGFT Notification No. 22/2026-27, issued just ten days earlier, which empowered the Central Government to prohibit the import of goods manufactured using forced labour. While the notification created the legal authority, Para 2.50A now provides the enforcement process.

What Does Para 2.50A Provide?

The newly inserted provision lays down a structured investigation framework:

1. DGFT Can Initiate an Investigation

An enquiry may begin either:

Suo motu (on DGFT’s own initiative), or
Based on a complaint supported by credible evidence.

2. Power to Seek Information

DGFT may require information, documents, and clarifications from:

Importers
Exporters
Manufacturers
Any other relevant person or authority

This enables the authority to examine the entire supply chain where necessary.

3. Consultation with Government Bodies

During an investigation, DGFT may consult relevant Ministries, Departments, and Government agencies to obtain necessary information and technical inputs.

4. Expert Assistance

DGFT may also seek assistance from domestic or international organisations, government bodies, and technical experts where specialised knowledge is required.

5. Findings and Recommendation

After completing the enquiry, DGFT will prepare a findings report. If forced labour is established, it may recommend to the Central Government that the concerned goods be prohibited from import under the Foreign Trade (Development and Regulation) Act, 1992 and the Foreign Trade Policy, 2023.

Why This Matters

Together, the recent DGFT measures create a complete regulatory framework for addressing forced-labour imports:

Notification No. 22/2026-27 gives the Government the power to prohibit imports made using forced labour.
Public Notice No. 21/2026-27 (Para 2.50A) establishes the investigation process required before such prohibitions are recommended.

In other words, the legal authority now has a clear procedural mechanism for enforcement.

The timing is also significant, as global trade is witnessing increased scrutiny of supply chains and ethical sourcing practices. Businesses importing into India should expect greater focus on supply chain transparency and documentation.

What Importers Should Do

Importers should proactively review their supply chains and maintain adequate records to demonstrate ethical sourcing. Businesses should consider:

Conducting supplier due diligence.
Maintaining traceability and manufacturing records.
Obtaining supplier declarations where appropriate.
Keeping documentation readily available for any DGFT enquiry.

Conclusion

The introduction of Para 2.50A marks an important development in India’s trade compliance framework. It transforms the recently introduced forced-labour import prohibition from a legal provision into an enforceable regulatory process.

Businesses engaged in international trade should closely monitor these developments and strengthen their supply chain compliance programmes to minimise regulatory risk.