The Royal Government of Cambodia adopted Inter-Ministerial Prakas No. 450 MEF.PrK dated 1 July 2026 on the Prohibition on Imports of Goods Linked to Forced Labor (the “Prakas”), which took effect on the same date. The Prakas establishes a coordinated regulatory framework addressing the importation of goods produced with forced labor, and is jointly administered and enforced by three ministries: the Ministry of Economy and Finance, the Ministry of Commerce, and the Ministry of Labour and Vocational Training.

Background
The Prakas was adopted against the backdrop of the United States Trade Representative’s (“USTR”) Section 301 investigation into the failure of various economies to impose and effectively enforce a prohibition on the importation of goods produced with forced labor. The USTR report, issued in June 2026, found that all 60 economies under investigation – including the European Union, Canada, and Mexico – either failed to effectively enforce a forced labor prohibition or failed to impose any legal prohibition on such imports. USTR subsequently proposed additional duties of 10% on products of economies that have undertaken commitments regarding forced labor import prohibitions, a category that includes Cambodia, and 12.5% for economies that have failed to impose and effectively enforce such a prohibition.
Following a consultative meeting with the Section 301 Committee on Forced Labor held on 15 May 2026 in Washington, D.C., the Royal Government considered the Committee’s observations and relevant international practices, and responded by adopting the Prakas.

Scope of the Prohibition
The Prakas expressly provides that the import, use, circulation, or supply of goods linked to forced labor within the Kingdom of Cambodia is prohibited. Notably, the prohibition is not confined to the act of importation itself: the subsequent use, circulation, and supply of such goods within Cambodia also fall within its scope.

Administrative Sanctions
Under Articles 7 and 8 of the Prakas, where imported goods are found to be linked to forced labor, their importation, use, circulation, and supply within Cambodia are prohibited. Where an importer is found to have imported such goods, administrative sanctions are imposed, including:
– Suspension of import and export activities
– Suspension of the issuance of Certificates of Origin
– Other measures in accordance with applicable laws and regulations
The suspension of Certificate of Origin issuance is a particularly significant consequence for export-oriented enterprises, as it may affect the ability to claim preferential tariff treatment and, in practical terms, to export at all.

Existing Legal Framework
Cambodia’s prohibition of forced labor is not new in itself. Article 15 of the Labour Law prohibits forced or compulsory labor in all sectors, reflecting ILO Convention No. 29, which Cambodia ratified in 1969. The Prakas complements this domestic prohibition by extending regulatory attention to goods entering Cambodia through its supply chains.

Implementation Considerations
Enterprises importing raw materials, components, or finished goods into Cambodia should review their supply chains and supplier due diligence processes in light of the Prakas. Manufacturers producing for export, in particular, should note that the sanctions extend to the suspension of Certificates of Origin, which could disrupt export operations. Given that the Prakas is newly effective and jointly administered by three ministries, the practical enforcement approach – including how goods will be determined to be “linked to forced labor,” what evidentiary standards will apply, and what remediation or rebuttal opportunities will be available to importers – remains to be clarified through implementation practice and any subsequent guidance.
Enterprises whose parent companies are already subject to comparable regimes – such as the U.S. Uyghur Forced Labor Prevention Act or the EU forced labor regulation – may be able to leverage existing group-level supply chain due diligence frameworks in preparing for compliance in Cambodia.

For Assistance
Importers, manufacturers, trading companies, and retailers operating in Cambodia should consult with their legal advisors to assess the implications of the Prakas for their supply chains and import operations, and to monitor further developments as the enforcement framework takes shape.