The Trump administration in the United States has begun a Section 301 investigation aimed at blocking imports of goods produced through forced labor from 60 countries, South Korea included. Although South Korea is on the list of countries under scrutiny, analysts suggest that the likelihood of it being directly targeted in the investigation is low. However, concerns have arisen that South Korean products containing cobalt, lithium, and rare earth elements with potential ties to forced labor could expose them to indirect liability under a 'joint responsibility' framework.

Jamie Greer, the U.S. Trade Representative, emphasized the importance of cracking down on products made by forced labor, noting that governments have failed to effectively prevent these goods from entering their markets. He stated that foreign producers who gained an advantage through forced labor are currently forcing competition against U.S. workers and companies. Experts believe that although South Korea is unlikely to be a direct target of the forced labor investigation, the country’s dependence on raw materials sourced from high-risk forced labor regions raises serious concerns.

Notably, South Korea relies heavily on imports of rare earth materials, over 90% of which come from China, with a significant portion being sourced from the Xinjiang region where forced labor is prevalent. Furthermore, cobalt, which is necessary for phone production, may be tied to child labor in the Democratic Republic of the Congo, and lithium, crucial for battery production, has been flagged by the U.S. Department of Homeland Security as a priority monitoring material. Even if South Korea itself isn't directly implicated in forced labor practices, any confirmation of contaminated supply chains involving forced or child labor could place South Korean firms under scrutiny for joint liability by U.S. authorities.