A first estimate for one plant or product line, covering the first two steps of an exposure assessment. Enter what workers paid in fees, what the product earns, and which groups would act if goods were held. The calculator shows what you would owe workers, the profit at risk while you wait for the order to be lifted, the knock-on costs from other groups, and what it would cost to fix the problems first instead.
The calculator runs in your browser. Nothing you enter leaves your computer or is saved.
Start with the groups you rated High in Step 1, the ripple map. The figures already loaded are an illustrative scenario: one plant with 1,000 workers hired through agents that charge fees, selling into a market with a forced labour import ban. They do not describe any real company and are not a benchmark. Replace them with your own figures, or clear them and start from zero. Published benchmarks appear next to the inputs they relate to, with a numbered source.
Changing the currency changes the labels only. Benchmarks are shown in the currency of their source.
01 · Repaying workers
Who would be owed, and how much
US Customs expects workers to be repaid for every forced labour indicator found, not only for recruitment fees. Repayment covers current and former workers employed in the review period, which is at least the two years before the order took effect. A third-party financial auditor must confirm the list of workers and the amounts.1 Impactt’s repayment guidelines add the interest workers paid on loans and accept workers’ accounts without receipts. As best practice, they repay everyone who paid, in one payment within a month.2
Workers
What each worker paid
Back pay per worker
Back pay covers the other forced labour indicators: overtime paid below the legal rate, deductions workers did not agree to, and wages or deposits held back.1 Calculate it from wages, or enter a figure you already have.
Back pay per worker—
The cost of proving the repayment
These are illustrative figures. Replace them with quotes. These costs apply whether you fix the problems first or an order comes first.
Total owed under each standard
Choose which standard the comparison uses. The table shows all three.
Standard
Workers
Average per worker
Total owed
02 · Time until the order is lifted
How long it would take to get the order lifted
US Customs sets no timetable. It “requires clear evidence demonstrating full remediation” and “will not prescribe corrective actions”.1 In the four published cases cited here, orders were lifted 12 to 25 months after they were issued.6,7,8,9 Repaying workers is quick. Assembling the evidence takes longer. Check what you could show today.
What you could show today
0/8
Our reading of the published cases, not a prediction.
Months until the order is lifted
Published cases:
What the order would cost under each published timeline, with all other inputs as entered.
Case
Months
Cost if an order comes first
Extra cost of waiting
03 · Lost profit and held goods
What you lose while goods are held
Under a US withhold release order, the importer of record has three months to prove the goods may enter. It pays for storage throughout, may have to post a bond of three times the goods’ value, and otherwise must re-export or destroy the goods.3 Under the EU Forced Labour Regulation, from 14 December 2027, a decision requires products already on the market to be withdrawn and disposed of.4,5 The loss is lost profit (gross margin), not lost revenue, and it falls on the plant whose products cannot be shipped.
Profit lost while waiting for the order to be lifted
Goods caught when the order is issued
Lost profit and goods—
Already in force: the Section 301 forced labour duty
This duty is not caused by an order, so it is not included in the totals. Since 24 July 2026, the US has charged extra Section 301 duties on imports from 60 economies that it found had not banned, or had not enforced a ban on, imports made with forced labour. Most pay 10% or 12.5% on top of the normal duty. For the EU and Taiwan, the duty tops up the total to 10%, and for Japan, South Korea and Switzerland, to 12.5%. Goods under Section 232 tariffs, goods from Canada and Mexico that qualify under the USMCA, and many listed products are excluded.19,20 The duties are being challenged in the US Court of International Trade. The case was argued on 30 September 2026, and no ruling had been issued by mid-October 2026.21
Section 301 duty a year—
04 · Knock-on costs
Who acts while you wait
An order affects far more than the port. Each group asks a version of the same question at a different time, and compares your answer with what you have already said in public. Put a cost on what you can. The checks show what you have not yet looked at.
WeeksCustomers
Next reviewLenders
Renewal or claimInsurers
Next index reviewInvestors
Months to yearsLegal claims
Customers
They ask: can you prove this shipment is free of forced labour, which plant made our product, and who pays for the delay? US Customs asks auditors to analyse purchasing practices, contracts and pricing pressure, so a buyer’s own terms become part of your evidence.1
Lenders
They ask: does the order trigger a loan review, breach a loan condition (a covenant) or end sustainability-linked pricing? Do the bank’s know-your-customer files record forced labour risk? US guidance tells banks that recruitment fees can “take years to repay”, and forced labour offences are among the crimes that can support a money laundering charge under US law.13,14
Insurers
They ask: are goods held by customs a covered loss? Product liability insurance covers defective products, not goods held by a government. Cargo, trade credit, business interruption and directors’ liability policies may or may not cover them. Settle this with your insurers before any loss.
Investors, ratings and public reporting
They ask: what did you know, when did you know it, and what did you publish? Ratings and indices can lag behind the facts. Some index rules use a controversy screen only to keep new members out, and remove existing members only for a separate screening status or a low ESG score.15 What you have already published becomes the standard for judging what you say next.
Legal claims, lawyers and the board
The legal routes: workers at a supplier may sue a brand in its home country, as the English Court of Appeal allowed before the case settled in 2026. In the US, a court has held that simply buying a product, “without more”, is not taking part in a venture with the seller. Consumer protection claims do not need any worker as a plaintiff.16,17,18
Knock-on costs—
05 · Fixing first
What fixing the problems first would cost
Repaying workers, and proving it, are owed either way. Once forced labour indicators have been found, workers can no longer be charged recruitment fees, so paying those costs yourself is also a cost either way. What fixing first avoids is everything an order adds on top. In 2020 and 2021, in the months after an order on a competitor, two glove makers repaid RM41 million and committed RM54 million to their workers.11,12 Another company estimated the fees owed to its workers at RM53 million. On an independent consultant’s recommendation, it committed about RM136 million.10 Treat your own estimate as a minimum.
Employer-paid recruitment—
How the sums work
How each figure is calculated
Per worker: fees paid at home and in the host country, plus interest on the borrowed share for the years the loans ran, plus back pay. Back pay is: months in the review period × (underpaid overtime hours × hourly rate × the gap between the overtime rate owed and the rate paid, plus monthly deductions), plus wages or deposits never returned. Back pay is applied in full to everyone in the review period, including those who left part-way through it, so it may overstate what leavers are owed.
Minimum: current workers × the amount per worker. US Customs requirement: current workers plus those who left in the two years before the order, plus the cost of tracing the leavers. Best practice: everyone who paid. Each also receives Impactt’s 3% a year for opportunity cost on their fees, compounded over the years since they paid. Earlier leavers receive their fees, loan interest and opportunity cost, but no back pay, because they left before the review period.
Owed either way: the amount owed to workers under the standard you choose, the cost of proving it, and paying recruitment costs yourself for new hires over the years compared.
Lost profit while goods are held: monthly gross margin for the months before another plant or supplier is approved, then the margin on the share of volume that cannot move, for the rest of the wait. Moving volume adds its own extra cost.
Goods: the share of goods at the border that is lost, plus storage. The bond is shown as money tied up, not as a cost.
Knock-on costs: margin on customers who do not come back, penalties while the order is in force, the higher interest on repriced debt, extra insurance premium after any recoveries, legal fees, claims and other costs.
If an order comes first is the total of everything above. If you fix before an order comes is what is owed either way. The difference is the extra cost of waiting.
What it leaves out
Treat the result as a minimum
Effects beyond one plant: other plants that use the same agents, and the same product reaching other countries’ borders.
Escalation. A withhold release order can be upgraded to a finding, which allows the goods to be seized.7
Management time beyond what you enter, lost future bids, and higher borrowing costs after a rating or index change.
The fall in share value on announcement. This is shown separately and not added to the totals.
Repeat problems. If the way you recruit does not change, the fees and the risk come back.
Any view on whether forced labour indicators are present. The calculator assumes they are found and estimates what follows.
Then
A full assessment tests these inputs: fee data for individual workers, the contract terms that apply if goods are held, and the evidence you could produce in thirty working days. See how it works.
Key figures and where they come from
Sources
Every benchmark on this page has a linked, publicly available source. Where a figure is derived, the calculation is shown.
1A review period of at least two years before the order; a list of all current and former workers owed repayment for every forced labour indicator; a third-party financial auditor; a verification audit; interviews in workers’ own languages using translators the company does not employ; a complaints system workers trust; worker involvement; a review of purchasing practices, customer contracts and pricing pressure; back wages as one form of repayment. US Customs “requires clear evidence demonstrating full remediation” and “will not prescribe corrective actions”.US Customs and Border Protection, Withhold Release Order (WRO) and Finding Modifications Guide, Publication 5040-0525, June 2025, pp. 2–11. PDF; summary by Crowell & Moring, June 2025.
2Minimum: workers employed when fee-charging was first identified, repaid within 3 to 9 months. Best practice: all current and former workers who paid, whenever they were recruited, in one payment within a month, with 3% a year compound interest for opportunity cost. Interest workers actually paid on loans is added; 40% a year is “not uncommon”. Workers’ accounts count without receipts; no waivers; amounts publicly disclosed and independently verified. Buyers that benefited from lower costs should consider sharing the cost.Impactt, Principles and Guidelines for the Repayment of Migrant Worker Recruitment Fees and Related Costs, October 2021 (version 1). PDF. Impactt published a version 2 in 2024, available from Impactt after registration.
3Three months to prove the goods may enter; storage at the importer’s cost; a possible bond of three times the value of the goods; audits should cover the ILO’s 11 forced labour indicators, and audits that do not are generally not considered sufficient.US Customs and Border Protection, Forced Labor Enforcement Operational Guidance for Importers, Publication 5560-0526, 9 June 2026, pp. 27–29 and 47. PDF
4The ban applies from 14 December 2027 to any company placing a product on the EU market, making it available there, or exporting it.Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market. EUR-Lex. The European Commission published its implementation guidelines in June 2026.
5Products already on the market can be ordered to be withdrawn and disposed of; products already with end users are not affected; the Commission will keep a database of forced labour risk areas and products.Clifford Chance, EU ban on products made with forced labour makes its way into law, 24 February 2025. Link
6YTY Group: order 28 January 2022, lifted 8 February 2023, about 12 months, after a corrective action plan, repayment of recruitment fees, an independent social compliance audit and supporting documents.US Customs and Border Protection, 8 February 2023. Link
7Top Glove: order 15 July 2020, upgraded to a finding 29 March 2021, lifted 9 September 2021, about 14 months. More than US$36.3 million repaid to 12,676 current and eligible former workers, about US$2,860 each (derived: 36.3 million ÷ 12,676), verified by an independent firm that also ran a worker helpline.US Department of Labor, Bureau of International Labor Affairs, Example in Action: Top Glove WRO and Subsequent Modification. Link; and the finding of 29 March 2021, CBP
8Supermax: order 21 October 2021, lifted 18 September 2023, about 23 months.US Customs and Border Protection, 19 September 2023. Link
9Sime Darby Plantation: order 30 December 2020, upgraded to a finding 28 January 2022, lifted 3 February 2023, about 25 months.US Customs and Border Protection, 3 February 2023. Link
10The company’s own estimate was RM53 million; about RM136 million was committed on an independent consultant’s recommendation.Top Glove, Top Glove raises remediation payment to migrant workers, 6 October 2020. Link
11RM41 million in recruitment fees repaid, November 2020 to June 2021.Free Malaysia Today, Hartalega repays its workers RM41mil in agents’ fees, 8 June 2021. Link
12RM54 million repayment programme announced 1 October 2020; RM29 million paid by 10 June 2021, with the remaining RM25 million brought forward to the end of June 2021.Malaysian Rubber Board, reporting a Kossan Rubber Industries filing, June 2021. Link
13Recruitment fees “can range from hundreds of dollars to tens of thousands of dollars, and take years to repay”.FinCEN, US Department of the Treasury, Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity, FIN-2020-A008, 15 October 2020, p. 4. PDF
14Peonage, slavery, forced labour and trafficking offences count as “racketeering activity”, and so can support a money laundering charge.18 U.S. Code §§ 1961(1) and 1956(c)(7). § 1961, § 1956
15The controversy screen applies only to companies joining the index; existing members are not removed for it. Existing members are removed for a “Non-compliant” screening status, or if their ESG score stays below the minimum (2.9 in developed markets, 2.4 in emerging markets) for a year.FTSE Russell, FTSE4Good Index Series Ground Rules, v6.2, October 2026, rules 6.1.5, 6.2.2, 6.2.3, 6.3.7 and 6.4.7. PDF
16The Court of Appeal held that England was the right place for workers at a brand’s overseas suppliers to bring their claims (December 2024). A settlement was announced on 26 February 2026, with no admission of liability.Limbu and others v Dyson [2024] EWCA Civ 1564, judgment; Leigh Day, settlement announcement
17“Purchasing a commodity, without more, is not ‘participation in a venture’ with the seller.”Doe v. Apple Inc., No. 21-7135 (D.C. Cir. 2024). Justia
18A consumer protection claim about a company’s statements on child labour in its supply chain. It seeks an injunction, not damages, and the company denies the allegations.International Rights Advocates v. Lindt & Sprüngli (USA and North America), complaint filed 8 May 2026. Case page
19Section 301 forced labour duties on imports from 60 economies, announced 23 July 2026 and in force from 24 July 2026.Office of the US Trade Representative, July 2026. Press release
20Rates: 10% on top of the normal duty (for example Canada, Mexico, India, the UK); a top-up to a combined 10% (the EU and Taiwan); a top-up to a combined 12.5% (Japan, South Korea, Switzerland); 12.5% on top for all other covered economies (for example China, Vietnam). Excluded: goods already under Section 232 tariffs, USMCA-qualifying goods from Canada and Mexico, and listed products such as energy, critical minerals, pharmaceuticals and semiconductors.Thomson Reuters, U.S. imposes Section 301 forced-labor tariffs on imports from 60 economies, 24 July 2026, link; Greenberg Traurig, July 2026, link
21In re Section 301 Forced Labor Cases, US Court of International Trade, No. 1:26-cv-03555: argued 30 September 2026; no decision issued, and the duties remain in effect.Troutman Pepper Locke, Getting Duties Back: Where Recovery Stands Under IEEPA, Section 122, and Section 301 Forced Labor Tariffs, 12 October 2026. Link
General commentary for discussion. This is not legal, tax or investment advice. The calculator is a planning tool, not a forecast, and the illustrative scenario does not describe any real company. Sources were last checked on 28 October 2026. See our terms of use.
