Child Labour and Forced Labour Monitoring in Pakistan: What International Buyers Must Understand Under EU CSDDD

Where the evidence of risk is strongest

Cotton farming in Sindh and Punjab is the supply chain tier with the most documented child labour risk in Pakistan's textile-relevant economy. The ILO, Human Rights Watch, and Pakistan's own Bonded Labour Liberation Front have published research documenting child labour in cotton picking, particularly seasonal picking that coincides with school terms in Pakistan's agricultural calendar. The pattern is typically: cotton harvest requires labour-intensive hand picking during a specific seasonal window. Agricultural families, particularly those in debt or with limited economic alternatives, may involve children in picking alongside adults during this period. Children miss school during harvest season.

This is not universal across all Pakistani cotton farming. It's concentrated in specific socioeconomic contexts, particularly among marginalized agricultural communities with limited access to education alternatives and limited economic security. Better Cotton Initiative Pakistan, which operates specifically in Pakistan's cotton-growing regions, has farmer training and monitoring components that specifically address child labour and other decent work issues.

Home-based embellishment work, which contributes to higher-value Pakistani garments, particularly in ethnic wear, occasion wear, and artisan categories, involves children in some documented contexts. The pattern here is family-based production where embroidery and beadwork are skills passed within families, and where children may participate in production as part of family economic activity. The informality of home-based work, and its invisibility to factory-based social audit programmes, means monitoring is structurally difficult.

Brick kilns in Pakistan have documented bonded labour practices, including debt bondage that entraps entire families, and child labour within those bonded labour situations. Brick kilns are not part of the textile supply chain directly, but they supply construction materials to factories. Whether a buyer's factory was constructed using brick kiln products is a legitimate supply chain diligence question under CSDDD's "value chain" framing.

Where the risk is demonstrably lower

Formal, export-oriented Tier 1 garment factories with international buyer relationships represent the lower-risk tier for child and forced labour. These facilities have commercial incentives to maintain compliance: buyer relationships that depend on social audit outcomes, the reputational stakes of a compliance failure in a major export relationship, and regular SMETA or BSCI audits that create accountability.

This doesn't mean zero risk. Overtime pressure during peak production periods, restricted freedom of association in some facilities, and gaps in hazard pay for chemical exposure in some contexts are issues that SMETA audits do identify at Pakistani Tier 1 facilities. But systematic child labour and forced labour are rare at this tier, and the monitoring infrastructure is more developed than at sub-tiers.

What CSDDD actually requires for Pakistan-specific risk

The CSDDD is clear that the due diligence obligation extends to the value chain, not just to direct Tier 1 suppliers. For Pakistan, this creates a tiered obligation: At Tier 1: comprehensive due diligence. SMETA audits, supplier code of conduct compliance, worker voice mechanism verification, and grievance mechanism assessment. This tier has the most buyer leverage and the strongest contractual relationship.

At Tier 2 (processing sub-contractors, dye houses): due diligence proportionate to the risk and to the buyer's influence. Buyers don't have direct contracts with Tier 2 facilities. But they have contractual leverage over Tier 1 suppliers, who can be required to flow down code of conduct requirements and disclose their sub-contractors. Extending social audit coverage to high-risk Tier 2 facilities is an appropriate measure.

At the cotton farming tier: CSDDD's "plausible adverse impact" language, and its "exercise of influence" concept, apply here. Buyers don't audit cotton farms. But they can support Better Cotton Initiative participation by their suppliers, include Better Cotton in sourcing requirements, and contribute to industry-level programmes that address farming tier labor conditions.

The income remediation requirement: specific to Canada and CSDDD

Both Canada's Fighting Against Forced Labour Act and the CSDDD framework include specific language about remediation. When a buyer identifies that their intervention has removed children from work or has disrupted income to vulnerable families (for example, by requiring a supplier to terminate home-based workers), there is an obligation to consider the impact on those families and to support transition.

This is an operational consideration. Requiring a supplier to stop using home-based embellishment workers, without any support for those workers transitioning to other income sources, may be the right compliance action in the narrow legal sense but potentially causes more harm to vulnerable workers than careful, programmatic transition support would.

The most credible approach in Pakistan's context: engage suppliers in a programme to identify home-based workers in the supply chain, understand their economic context, connect them with legitimate local support organizations or Fair Trade programmes where applicable, and develop a transition plan that maintains income while improving formal labor conditions.

The honest assessment: where most buyers are and what's missing

Most international buyers sourcing from Pakistan have Tier 1 social audit coverage and a supplier code of conduct. Most have not systematically mapped their Tier 2 supply chain or extended due diligence to the cotton farming tier.

This represents a gap that is now legally relevant under CSDDD for EU buyers, UK MSA for UK buyers, and Canadian law for Canadian buyers. The gap doesn't require an impossible expansion of supplier audit programmes. It requires specific additional steps: sub-contractor disclosure requirements, Better Cotton programme engagement for cotton-origin products, extension of audit scope to high-risk Tier 2 facilities, and documentation of proportionate measures taken at each tier.

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