About a month has passed since Decree 1444 of 2026 entered into force, and its implementing regulations, including the registry of indicative risk lists, have not yet been issued.

However, the ban on importing goods linked to forced labor is already in force, and waiting for the regulations to be issued may be too late for importers to act properly: the due diligence that exempts importers from liability must be documented before importing, and the burden of proving it lies with the importer.

We therefore recommend that importers take at least the following steps now, inspired by U.S., EU and OECD practice, which are likely to serve as a reference for the forthcoming regulations:

1. Map the operation: inventory the tariff subheadings, suppliers, manufacturers and countries of origin of imports over the last 24 months, distinguishing them from the countries of shipment, since risk travels with the input and not with the port of shipment;
2. Identify critical inputs and screen them against international lists: determine the sensitive inputs (for example, the cotton in a garment or the polysilicon in a solar panel) and check them against the UFLPA Entity List, U.S. Customs Withhold Release Orders, the U.S. Department of Labor TVPRA list and decisions adopted under Regulation (EU) 2024/3015;
3. Prioritize by risk level: focus efforts on the highest-exposure chains, such as cotton and apparel, polysilicon and solar panels, tomatoes, aluminum and auto parts, PVC and seafood, and trace the origin of the input as far as the risk requires;
4. Adopt a policy and assign responsibilities: have the board of directors or senior management approve a forced labor prohibition policy applicable to suppliers and subcontractors, and appoint a foreign trade compliance officer;
5. Amend supplier contracts: include forced labor prohibition clauses, origin declarations for critical inputs, sub-supplier disclosure, audit rights, notification of inclusion in lists and cooperation in providing documents to DIAN;
6. Use questionnaires and verify suppliers: request a due diligence questionnaire signed by the legal representative and, for the highest-risk chains, order unannounced audits or verification by independent third parties;
7. Build a traceability file: gather, lot by lot, the documents needed to reconstruct the path of the critical input from its origin to the imported goods, so that it can be delivered within 15 business days of a request; and
8. Set a response protocol and monitor developments: establish how to act upon an alert or a DIAN action, and review domestic and foreign lists at least quarterly, as well as any additional regulations as they are issued.

These measures will allow your company to adapt quickly to the regulations once issued. The importer's defense is built now, not after Decree 1444 of 2026 is regulated.

Our Customs and International Trade team is available to assist you.