FAR 22.1503—Procedures for acquiring end products on the List of Products Requiring Contractor Certification as to Forced or Indentured Child Labor.
Plain-English Summary
FAR 22.1503 explains how contracting officers and offerors handle acquisitions involving end products that appear on the Department of Labor’s List of Products Requiring Contractor Certification as to Forced or Indentured Child Labor. It covers when the contracting officer must check the List, what the List means, the country-of-origin and dollar-value exceptions that remove certain acquisitions from these requirements, the certification offerors must provide for listed end products, how the contracting officer may rely on that certification, when suspected violations must be referred for investigation, and the fact that a proper certification does not eliminate later remedies if forced or indentured child labor is actually discovered. In practice, this section is a screening and certification procedure designed to prevent the Government from unknowingly buying products tied to forced or indentured child labor while still allowing purchases where the FAR’s trade agreement or country-specific exceptions apply. It also creates a clear workflow for solicitation drafting, offeror certification, award decisions, and post-award enforcement. For contractors, the section means they must either confidently certify non-use of forced or indentured child labor for listed products or document a good-faith inquiry and lack of knowledge. For contracting officers, it means checking the List, inserting the right certification language, applying the exceptions correctly, and escalating credible concerns when they arise.
Key Rules
Check the DOL List
When issuing a solicitation for supplies expected to exceed the micro-purchase threshold, the contracting officer must check the Department of Labor’s List of Products Requiring Contractor Certification as to Forced or Indentured Child Labor. The List is an alert mechanism, not an automatic prohibition on buying the product.
List Is Not a Purchase Ban
A product’s appearance on the List does not bar purchase of that product from the identified country. Instead, it signals a reasonable basis to believe the product may have been mined, produced, or manufactured with forced or indentured child labor.
Country-and-Value Exceptions Apply
The certification requirements triggered by the List do not apply to certain acquisitions from listed countries when the anticipated value meets the applicable threshold: Israel at $50,000 or more, Mexico at $105,767 or more, and specified trade-agreement countries at $174,000 or more. These exceptions must be applied before requiring the child-labor certification.
Offeror Must Certify for Listed End Products
Except where paragraph (b) applies, the offeror must certify before award for any end product of a type identified by country of origin on the List. The certification is either a promise not to supply listed end products from the identified country, or a statement that the offeror made a good-faith effort to determine whether forced or indentured child labor was used and is unaware of any such use.
Contracting Officer Relies on Certification
Absent actual knowledge that the certification is false, the contracting officer must rely on the offeror’s certification when making the award decision. The CO is not required to independently prove compliance before award unless there is actual knowledge of falsity.
Suspected Violations Must Be Referred
If the contracting officer has reason to believe forced or indentured child labor was used for an end product furnished under a contract subject to the certification requirement, the matter must be referred for investigation to the appropriate authority under agency procedures, such as the Inspector General, Attorney General, or Secretary of the Treasury. This referral duty does not apply to the paragraph (b) exception cases above the applicable threshold.
Certification Does Not Eliminate Remedies
Even a proper certification does not prevent the agency head from imposing remedies under FAR 22.1504(a)(4) if it is later discovered that the contractor furnished an end product or component that was in fact mined, produced, or manufactured wholly or partly using forced or indentured child labor.
Responsibilities
Contracting Officer
Check the DOL List when issuing solicitations for supplies expected to exceed the micro-purchase threshold; determine whether any country-of-origin and dollar-value exceptions apply; include the required certification language in the solicitation; rely on the offeror’s certification unless there is actual knowledge it is false; and refer suspected violations for investigation when there is reason to believe forced or indentured child labor was used.
Offeror/Contractor
For covered acquisitions, certify either that it will not supply any listed end product mined, produced, or manufactured in the identified country, or that it made a good-faith effort to determine whether forced or indentured child labor was used and is unaware of any such use; and ensure the certification is truthful and supported by reasonable inquiry.
Agency Head
May impose remedies under FAR 22.1504(a)(4) if it is later discovered that the contractor furnished an end product or component actually produced with forced or indentured child labor, even if the contractor had properly certified earlier.
Inspector General / Attorney General / Secretary of the Treasury
Investigate matters referred by the contracting officer when there is reason to believe forced or indentured child labor was used, in accordance with agency procedures and the appropriate jurisdictional assignment.
Agency
Establish procedures for determining the appropriate investigative authority and for handling referrals and follow-on enforcement actions when suspected violations arise.
Practical Implications
Contracting officers must treat the List as a required screening step, not an optional reference, whenever buying supplies above the micro-purchase threshold.
The country-of-origin exceptions are easy to misapply; the key is both the country and the acquisition value threshold, so COs should verify the correct threshold before requiring certification.
Offerors should not treat the certification as a mere formality: they need a real good-faith supply-chain inquiry for listed products, especially where sourcing is complex or multi-tiered.
A clean certification does not end the risk; if later evidence shows forced or indentured child labor was actually used, the agency can still pursue remedies and enforcement actions.
If a CO has credible concerns, the issue should be escalated promptly rather than handled informally, because the FAR requires referral when there is reason to believe a violation occurred.
Official Regulatory Text
(a) When issuing a solicitation for supplies expected to exceed the micro-purchase threshold, the contracting officer must check the List of Products Requiring Contractor Certification as to Forced or Indentured Child Labor (the List) ( www.dol.gov/ilab/ ) (see 22.1505 (a)). Appearance of a product on the List is not a bar to purchase of any such product mined, produced, or manufactured in the identified country, but rather is an alert that there is a reasonable basis to believe that such product may have been mined, produced, or manufactured by forced or indentured child labor. (b) The requirements of this subpart that result from the appearance of any end product on the List do not apply to a solicitation or contract if the identified country of origin on the List is- (1) Israel, and the anticipated value of the acquisition is $50,000 or more (see 25.406 ); (2) Mexico, and the anticipated value of the acquisition is $105,767 or more (see subpart 25.4 ); or (3) Armenia, Aruba, Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hong Kong, Hungary, Iceland, Ireland, Italy, Japan, Korea, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Moldova, Montenegro, Netherlands, New Zealand, North Macedonia, Norway, Poland, Portugal, Romania, Singapore, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Taiwan, Ukraine, or the United Kingdom and the anticipated value of the acquisition is $174,000 or more (see 25.402 (b)). (c) Except as provided in paragraph (b) of this section, before the contracting officer may make an award for an end product (regardless of country of origin) of a type identified by country of origin on the List the offeror must certify that- (1) It will not supply any end product on the List that was mined, produced, or manufactured in a country identified on the List for that product, as specified in the solicitation by the contracting officer in the Certification Regarding Knowledge of Child Labor for Listed End Products; or (2) (i) It has made a good faith effort to determine whether forced or indentured child labor was used to mine, produce, or manufacture any end product to be furnished under the contract that is on the List and was mined, produced, or manufactured in a country identified on the List for that product; and (ii) On the basis of those efforts, the offeror is unaware of any such use of child labor. (d) Absent any actual knowledge that the certification is false, the contracting officer must rely on the offerors’ certifications in making award decisions. (e) Whenever a contracting officer has reason to believe that forced or indentured child labor was used to mine, produce, or manufacture an end product furnished pursuant to a contract awarded subject to the certification required in paragraph (c) of this section, the contracting officer must refer the matter for investigation by the agency’s Inspector General, the Attorney General, or the Secretary of the Treasury, whichever is determined appropriate in accordance with agency procedures, except to the extent that the end product is from the country listed in paragraph (b) of this section, under a contract exceeding the applicable threshold. (f) Proper certification will not prevent the head of an agency from imposing remedies in accordance with section 22.1504 (a)(4) if it is later discovered that the contractor has furnished an end product or component that has in fact been mined, produced, or manufactured, wholly or in part, using forced or indentured child labor.