A new report from Built Environment Declares and HACE highlights gaps in the construction sector’s approach to child labour risks. With several TDUK members among its authors, ‘Impacts of Child Labour in Construction Materials’ sets out why the industry should look beyond existing modern slavery measures, improve supply-chain transparency and take a more proactive approach to identifying and addressing child labour risks in material supply chains.
Written by built-environment professionals and specialists in child labour, including representatives from Structural Engineers Declare, Architects Declare, Ramboll, Buro Happold, WSP and the Alliance for Sustainable Building Products, the report identifies a significant gap in the construction sector: the lack of a mature market for ethically traded materials, with limited transparency and insufficient attention to the social impacts of sourcing.
Why modern slavery measures aren’t enough
The report highlights an important distinction: that under UK law child labour is not synonymous with modern slavery or forced labour. This means that the existing measures for tackling modern slavery (the UK Modern Slavery Act 2015) do not identify all child labour risks.
While forced child labour does occur, the report shows that child labour frequently happens independently of forced labour. Citing HACE and US Department of Labor research from 2025, it states that 72.7% of commodity- and country-level risks relate exclusively to child labour, with no overlap with forced labour or modern slavery. This means businesses relying solely on modern slavery due diligence may be overlooking significant risks in their supply chains.
For timber businesses, this is both an ethical responsibility and a business concern. Companies need to understand where their products originate, what risks may exist further down their supply chains, and whether their existing due-diligence processes are enough to identify and address those risks.
Where risks arise in timber supply chains
Child labour – defined as “work that is mentally, physically, socially or morally dangerous and harmful to children; and interferes with their schooling” (International Labour Organisation, 2023) – affects an estimated 138 million children worldwide and is embedded in a range of global supply chains. The report examines construction materials where child labour is a demonstrated risk, including brick, sandstone, extractive minerals, renewable energy infrastructure and plywood.
A recurring finding is that risks are often concentrated further down the supply chain, at the raw-materials stage. The report highlights the difficulty of assessing risks through UK import data alone, particularly where potentially high-risk raw materials are incorporated into finished or semi-finished products before entering the UK.
For timber products, this underlines the importance of understanding provenance and looking beyond immediate supplier relationships to get visibility of earlier stages of production.
Plywood is identified in the report as a particular traceability challenge. The UK relies heavily on imported plywood, and a significant proportion of imports originate outside the EU, including from China and Brazil. Plywood’s composite structure adds further complexity: individual sheets contain multiple veneer layers, making it harder to establish the provenance of each component.
Integrating social due diligence with environmental traceability
The report highlights that upcoming legislation to improve environmental supply-chain transparency could also help to address child labour risks in timber products. It points to the potential for the EU Deforestation Regulation (EUDR) – which requires supply chain mapping and traceability – to create opportunities for better identification of social risks as well as environmental ones. By integrating social considerations into mapping and traceability systems wherever possible, these processes could help identify child labour risks in a streamlined and efficient way.
Existing timber safeguards to build on
The timber sector also has established regulatory and certification frameworks that provide a foundation for addressing child labour risks, although their scope and requirements differ.
In the UK, timber due diligence under the UK Timber Regulation (UKTR) focuses on ensuring that timber has been harvested legally in its country of origin. While it doesn’t directly address child labour risks, it means that timber (unlike many other construction materials) already benefits from established processes for assessing sourcing risks and documenting supply chains. These can, and should, be built on to strengthen attention to social risks.
Voluntary certification schemes such as PEFC and FSC also provide important safeguards, with requirements that address aspects of social responsibility, including child labour. For example, PEFC’s Chain of Custody standard (PEFC ST 2002:2020) includes social, health and safety requirements. Clause 4.10 states that organisations must demonstrate that workers below the applicable minimum working age are not employed. PEFC’s provisions on controversial sources also extend upstream to forest activities that fail to meet the International Labour Organization’s fundamental-rights framework, including requirements on minimum working age and the minimum age for hazardous work. Where relevant risks are identified, due-diligence controls are intended to minimise the risk of material from controversial sources entering PEFC product groups.
Limitations in practice
Together, these existing measures provide a platform for progress, but they should not be taken as a guarantee that every child labour risk has been identified or eliminated.
In practice, businesses may commit to the responsible-sourcing principles of FSC or PEFC without following through with their due diligence duties across their supply chains. Regulatory enforcement is another challenge, with limited personnel making it harder to ensure that businesses meet their UKTR obligations, creating scope for some to cut corners or fail to investigate risks beyond their immediate suppliers.
Regional regulations also struggle to account for the different legal frameworks and circumstances of timber producing countries and communities, including the rights of Indigenous peoples.
These challenges are especially relevant in a sector made up of many small businesses, which may not have dedicated compliance teams or capacity to investigate human rights risks throughout complex international supply chains. As such, there is a need for clear, workable requirements, effective enforcement and practical support to help businesses of all sizes strengthen due diligence and address child labour risks more consistently.
What specifiers and suppliers can do
The report sets out a series of actions for different parts of the built environment, with practical implications for TDUK members supplying, specifying and purchasing construction materials.
For timber suppliers:
- Understand the origins of products and their constituent raw materials
- Assess child labour risks explicitly as part of supply-chain due diligence, rather than relying solely on modern slavery policies
- Include clear child labour expectations in supplier codes of conduct and procurement requirements
- Ensure auditing and compliance teams are equipped to identify child labour risks
- Work collaboratively with suppliers and specialist organisations to address risks and improve practices
For designers and specifiers:
- Ask where materials come from and seek reliable information about provenance
- Consider traceability and child labour risks when selecting materials
- Identify potentially higher-risk materials early, allowing appropriate due diligence
- Consider low-risk, traceable, local and recyclable materials as part of a broader responsible-materials strategy
For clients, developers and procurement teams:
- Set clear expectations on responsible sourcing and child labour in project briefs and procurement policies
- Make supply-chain transparency a routine part of procurement conversations
- Prioritise risk assessment and proportionate checks
- Work collaboratively with suppliers to identify problems and agree appropriate responses
What happens when a risk is identified?
Identifying risks is only the first step; the report emphasises that businesses then need to respond constructively when child labour is suspected or uncovered.
Avoiding higher-risk products or regions may sometimes be appropriate, but blanket bans and sudden withdrawal from a supply chain can have negative consequences, potentially destabilising livelihoods and leaving affected communities worse off. Instead, businesses should assess the nature of the risk and consider how it can best be addressed. This may involve working with suppliers, seeking specialist support and implementing corrective, child-centred remediation that prioritises the welfare and rights of affected children.
The report calls for risks to be assessed rather than ignored or hidden, for supplier codes of conduct to include explicit child labour provisions, and for auditing teams to be trained and empowered to identify the problem. It also highlights the importance of collaboration and learning from industries – such as textiles and food – that have developed more mature approaches to ethical sourcing.
Building on progress across the timber sector
The publication of Impacts of Child Labour in Construction Materials is an important contribution to a conversation the construction sector needs to have more openly. It presents a challenge for the whole construction industry, but it also identifies opportunities to build on practices and frameworks that are already established in timber.
Existing timber due diligence, certification and traceability systems can help address supply-chain risks and provide a platform for further progress. Some TDUK members are already incorporating child labour considerations into their due diligence processes under the Responsible Purchasing Policy (RPP). Building on these efforts, the next step is to strengthen the consistent application of these approaches across the timber sector and look further down supply chains to understand risks associated with raw materials and composite products.
For TDUK members, this means continuing to strengthen responsible sourcing practices while working with designers, clients, procurers and other parts of the built environment to raise expectations across construction materials supply chains.
TDUK will continue to support its members in understanding these challenges and encourage collaboration across the built environment to strengthen responsible sourcing and help eliminate harmful practices from construction supply chains.
About the report
Impacts of Child Labour in Construction Materials was authored by Brogan MacDonald (Structural Engineers Declare, Ramboll), Eleanor Harry (HACE), Dr Natasha Watson (Built Environment Declares, Buro Happold), Mandy Franz (Architects Declare, MICA Architects), Emma Francois (Structural Engineers Declare, WSP), Elizabeth Burroughs (HACE) and Dr Asselia Katenbayeva (Alliance for Sustainable Building Products). Several presented the report at a recent webinar.
