Turkmenistan Forced Labour Allegations Resurface: What Brands Must Know for UFLPA / CSDDD Compliance

This article is for informational purposes only and does not constitute legal, compliance, or sourcing advice. Verify certification and regulatory requirements with the relevant standards body or counsel.

Editorial note: Reported by The Sourcing Desk editorial team. We cross-reference claims against standards-body publications, regulatory filings, and primary sourcing data. Published: 2026-06-02.

A new report from Cotton Campaign members Turkmen.News and the Turkmen Initiative for Human Rights, released in June 2026, documents the renewed, widespread mobilisation of public-sector workers — including teachers, doctors, and utility employees — to pick cotton or pay bribes to avoid field labour during Turkmenistan's most recent harvest, reversing what the coalition had previously described as partial progress under a formal cooperation roadmap with the International Labour Organisation (ILO).

The findings matter immediately to sourcing and compliance teams because the Uyghur Forced Labor Prevention Act (UFLPA), which established a rebuttable-presumption standard for goods linked to forced labour entering the United States, has been complemented since 2018 by a separate US trade ban on all Turkmen cotton and cotton products. The EU's Corporate Sustainability Due Diligence Directive (CSDDD), which requires in-scope companies to identify, prevent, and mitigate adverse human-rights impacts across their value chains, adds a parallel European compliance obligation. Cotton traceability — the ability to verify a finished garment's cotton content back through spinning and ginning to the farm of origin — is the operational capability that both regimes now demand.

According to the coalition, Turkmen cotton exports flow primarily to textile producers in Türkiye and Pakistan, but also reach manufacturers in Portugal and Italy. That routing means fibre can enter finished goods destined for US and EU markets through intermediary countries, creating a layered traceability challenge for brands that source from those hubs.

What this means for sourcing teams

The first step is supply-chain mapping down to the fibre level. Brands and retailers sourcing from mills in Türkiye, Pakistan, Portugal, or Italy should formally request country-of-origin documentation for raw cotton — not just yarn or fabric — and cross-reference it against known Turkmen export volumes. A supplier's word is not sufficient; third-party fibre-origin verification or certified chain-of-custody documentation is the minimum defensible standard.

For US-market goods, US Customs and Border Protection (CBP) enforces the existing Turkmen cotton ban and can detain shipments where origin cannot be disproven. Sourcing teams should review their Customs Trade Partnership Against Terrorism (CTPAT) and forced-labour compliance programmes to confirm Turkmenistan is explicitly listed as a restricted origin for cotton at the raw-material tier, not just at the country-of-manufacture tier.

For EU-market goods, CSDDD due-diligence obligations require documented risk assessments. Sourcing teams operating under CSDDD timelines should add Turkmenistan to their high-risk commodity registers alongside Xinjiang cotton and treat any supply-chain node in Türkiye or Pakistan as a potential transit point for Turkmen fibre until positive verification is in place.

Practical documentation to collect from suppliers includes: mill-level cotton purchase records with bale-origin data; third-party audit reports from accredited social-compliance auditors covering raw-material sourcing (not just cut-and-sew operations); and, where available, fibre-origin certifications from bodies such as the Better Cotton Initiative (BCI) or Textile Exchange's Organic Content Standard (OCS), which maintain chain-of-custody requirements that exclude undocumented origins. Note that neither BCI nor OCS operates in Turkmenistan, so their presence in a supply chain is a positive indicator — but only if the chain-of-custody documentation is unbroken back to the gin.

Brands that have not yet issued a formal restricted-origins policy for Turkmen cotton should do so now. H&M issued its ban on Turkmenistan cotton in 2016; the compliance baseline has existed for a decade. Brands still without an explicit policy are behind the curve and exposed.

What changed

The Cotton Campaign's 2024 report had already alleged state-imposed forced labour during the 2023 harvest, prompting renewed calls for import bans. The June 2026 report is significant because it documents a reversal: researchers allege that Turkmen authorities had made limited reductions in the deployment of doctors and teachers to the harvest in prior years, but those reductions have not been sustained. The 2025 harvest saw a return to systematic mobilisation, including documented instances of child labour working alongside family members in the fields.

The report also highlights structural drivers that make reform unlikely in the short term. Farmers operate under state-controlled quota systems with restricted access to irrigation and face demands for bribes. Climate pressures — hotter temperatures and water scarcity linked to the drying of the Aral Sea basin — are compounding production shortfalls, which in turn increase state pressure on workers to meet quotas.

Raluca Dumitrescu, senior coordinator for the Cotton Campaign Coalition with Global Labor Justice, called on governments with current or upcoming forced-labour import bans to formally classify Turkmen cotton as a commodity made with state-imposed forced labour. The ILO cooperation roadmap, while formally active, has not produced verifiable, sustained change on the ground according to the coalition's researchers.

For sourcing teams, the practical implication is that Turkmenistan cannot be treated as a reforming origin where enhanced monitoring is sufficient. The risk profile is closer to a blanket-exclusion scenario, consistent with how US trade law has treated it since 2018.

Limitations and open questions

Several regulatory and evidentiary questions remain open. The EU has not yet issued a formal commodity-level designation for Turkmen cotton equivalent to the US ban, and it is unclear whether CSDDD implementing guidance will name specific high-risk commodities or leave that determination to individual companies' risk assessments. Sourcing teams should monitor the European Commission's CSDDD delegated acts and sector-specific guidance, which had not been finalised as of this publication date.

The Cotton Campaign's findings, while detailed, are based on testimony from sources inside a closed authoritarian state where independent verification is structurally difficult. The Turkmen government has not publicly responded to the June 2026 report. The ILO has not yet published an updated assessment of its cooperation roadmap's outcomes for the 2025 harvest cycle.

Traceability technology — including isotope testing and DNA-based fibre origin verification — is increasingly available but not yet standardised or universally accepted by regulators as proof of origin. CBP has accepted isotope and DNA evidence in some UFLPA proceedings, but the evidentiary bar is set case by case. Brands investing in these tools should confirm with legal counsel that the methodology they use meets current CBP and, where applicable, EU evidentiary standards.

Finally, the report focuses on raw cotton. Downstream products — yarn, greige fabric, finished textiles — are harder to trace once Turkmen fibre is blended with other origins at the spinning stage. Mills in Türkiye and Pakistan that blend multiple cotton origins present the highest traceability risk, and standard social audits of those mills will not surface fibre-origin problems without specific raw-material procurement reviews.

This article is for informational purposes only and does not constitute legal, compliance, or sourcing advice. Verify certification and regulatory requirements with the relevant standards body or counsel.