Mexico Boosts Labor Checks

Mexico’s Ministry of Labor and Social Welfare (STPS) has issued an amended agreement significantly strengthening its authority to investigate imported goods suspected of involving forced or compulsory labour, including child labour.

The update grants new ex officio powers, enabling STPS to begin investigations without waiting for a complaint.

Changes Introduced by the Amendment

1. Stronger Enforcement Powers

• STPS can now initiate investigations independently.
• Authorities no longer require a third-party complaint to take action.

2. Simplified and Accessible Reporting

Complaints can be submitted through multiple channels:

• In-person filings • Email submissions • Mexico’s “Digital Window” online portal

These mechanisms improve accessibility and transparency for stakeholders reporting potential labour abuses.

3. Clear Investigation Procedures

The amendment establishes:

• Defined information requirements to start an investigation
• Specified response timelines
• Greater legal certainty for complainants and importers

USMCA Context

Under Article 23.6 of the USMCA (US, Mexico and Canada Agreement), the U.S., Mexico, and Canada must prohibit the importation of goods produced using forced or child labour.

Mexico introduced its own forced-labour import ban in 2023, but enforcement was limited due to procedural gaps.

The latest amendment closes those gaps, shifting Mexico from a nominal prohibition to a fully enforceable regulatory framework.

Impact on Importers and Global Supply Chains

1. Heightened Legal and Trade Risks

Imports into Mexico may be investigated if any part of the supply chain is linked to forced labour.

2. Mandatory Supply-Chain Due Diligence

Companies should now:

• Assess supplier labour practices
• Strengthen audit and verification documentation
• Maintain robust chain-of-custody and worker-welfare records

3. Potential Import Restrictions

Products associated with forced-labour activities may be blocked from entering Mexico, affecting sourcing, production continuity, and inventory flow.

4. Reputational & Compliance Implications

Non-compliance could lead to:

• Brand reputation damage
• Increased cross-border scrutiny under USMCA labour rules

Next Steps for Businesses

The amendment is already in effect (late October 2025).

STPS is preparing additional operational guidelines to support this new investigative model, and first ex officio investigations are expected soon.

Recommended Actions for Companies:

• Treat labour compliance as a trade-enforcement priority, not just an ethical commitment.
• Enhance supply-chain transparency and monitoring.
• Align labour-rights oversight with environmental, customs, and safety compliance programs.

Reference: Mexico Labour Compliance