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Sunday, May 3, 2026

Employers Liable When Contractors Exploit Child Labor, DOL Warns - Bloomberg Law

A new child labor enforcement initiative from the Biden administration is putting pressure on employers to reconsider their contract relationships, with the US Department of Labor vowing to go after all companies benefiting from child exploitation.

The practice of subcontracting out specific jobs or projects is often seen in the business community as a way to limit a company’s legal liabilities. But subcontracting firms caught violating child labor laws have put large US companies in legal and reputational trouble as they get caught up in a new crackdown from the US Departments of Labor and Health and Human Services.

Last month, those agencies announced an enforcement initiative to reverse an alarming uptick in exploitative child labor practices, as well as the formation of an inter-agency taskforce to help coordinate their work on the issue.

Management-side attorneys and one former DOL official caution that companies can’t claim ignorance that their contractor was violating federal labor laws as a defense against a federal probe into their hiring practices, and that the Biden administration’s new enforcement focus suggests the hiring company could be on the hook for their contractor’s violations, too.

“Under the initiative, employers may not defend against the DOL investigation by simply disclaiming direct knowledge of the use of illegal child labor,” said Catherine Barbieri, co-chair of the Labor &...



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