The Colombian Government issued Decree 1444 of September 28, 2026, which prohibits the import of goods produced through forced or compulsory labor.
Decree 1444 is part of a global trend of import bans on goods produced with forced labor. In the United States, the Uyghur Forced Labor Prevention Act (UFLPA) presumes that all goods originating from Xinjiang were produced with forced labor. The European Union is advancing its Regulation on the Prohibition of Forced Labor Products. The 2024 TVPRA List from the U.S. Department of Labor added 72 new goods from 82 countries. Colombian companies with exposure to international markets should consider these cross-cutting regulations.
- The import ban means that any goods that have been wholly or partially extracted, produced, manufactured, or transformed through forced or compulsory labor may not be imported into Colombia. This prohibition extends to all stages of the supply chain, including extraction, cultivation, harvesting, manufacturing, assembly, processing, and finishing.
- If goods produced through forced or compulsory labor are imported, they may be subject to seizure and confiscation, and the importer may face fines of up to 1,000 UVT per transaction (approximately COP $52,374,000).
- DIAN is the competent authority to oversee compliance with this prohibition, supported by the Ministry of Trade, Industry, and Tourism, as well as the Ministry of Labor.
- The Decree establishes that the following may be used as sources of information on forced labor: information provided by national or foreign authorities, reports from international organizations, judicial decisions, information from customs authorities’ risk management systems, complaints, petitions, or reports from individuals, among others.
The issuance of this Decree requires importing companies to review their supply chains and strengthen their due diligence processes to ensure that the goods they import have not been produced through forced labor.
In turn, the Decree will allow domestic industry to access additional protection mechanisms when competitors are importing goods produced through forced labor.
In this regard, we recommend: (i) mapping suppliers and origins throughout the chain, including indirect suppliers; (ii) implementing or updating human rights due diligence programs with documentary traceability; (iii) incorporating in supplier contracts declarations, audit rights, termination clauses, and indemnities; (iv) preparing a response protocol for DIAN requirements; and (v) monitoring the indicative risk lists once published.
| Product | Origin |
| Rice: | India, Bangladesh, Brazil, Burma, Dominican Rep., Ecuador, Ghana, Kenya, Mali, Philippines, Tanzania, Uganda, Vietnam, Pakistan |
| Aluminum: | China (Xinjiang) |
| Cotton: | China (Xinjiang), Uzbekistan, Turkmenistan, Tajikistan, Kazakhstan, Benin, Burkina Faso, India, Pakistan, Turkey, Azerbaijan |
| Palm Oil: | Indonesia, Malaysia |
| Cocoa: | Ivory Coast, Ghana, Nigeria, Cameroon |
| Sugar: | Dominican Rep., Brazil, Bolivia, Burma, India |
| Electronics: | China, Malaysia |
| Textiles: | China, Bangladesh, Vietnam, India, Thailand, Mauritius, Argentina |
| Fish/Seafood: | Thailand, China, Taiwan, Burma, Indonesia, Ghana |
Brigard Urrutia can assist your company with: (i) diagnosing exposure in your supply chains and designing and implementing due diligence programs, contractual clauses, and protocols to demonstrate due diligence before DIAN; (ii) defense in control, seizure, and confiscation proceedings; and (iii) preparing and filing complaints and information before DIAN, the Ministry of Labor, or the Ministry of Trade, Industry, and Tourism, regarding goods allegedly produced with forced labor entering the market, in protection of fair competition and responsible supply chains.