The U.S. Department of Labor (DoL) decided to include Li-Ion batteries among the 158 goods it suspects are produced using forced or child labor in the 10th edition of its “List of Goods Produced by Child Labor or Forced Labor”. While the addition of Li-Ion batteries is not due to direct evidence of labor abuse in its final production, but evidence of human exploitation in cobalt mining. Cobalt is one of the key inputs in Li-Ion batteries.

“The information is out there for companies and consumers to leverage against regimes that promote and prop up exploitative labor practices,” Deputy Undersecretary for International Affairs Lee wrote in the report’s opening statement.

The International Labor Organization (ILO) estimates that 160 million children work in abusive conditions worldwide.

According to ILO’s report, 40,000 children work in the Democratic Republic of Congo’s (DRC) cobalt mines. The DRC supplies 70% of the world’s cobalt.

In the DRC, cobalt is produced both at large scale mines and small scale ones, where child labor are more common. Small scale mines account for 14%-30% of DRC’s cobalt production. Once extracted, cobalt from small-scale operations tends to be mixed with that of large-scale mining and refined in preparation for export.

“Due to the prevalence of child labor in mining this critical mineral, the Department of Labor placed cobalt, specifically referred to as ‘cobalt ore (heterogenite),’ on its List of Goods Produced by Child Labor or Forced Labor in 2009. Over a decade later, child labor persists and is increasingly linked to the global supply chain of products made with cobalt, including lithium-ion batteries that power our smartphones, laptops, and electric cars,” the DoL document says. “Cobalt ore is heavily concentrated in one country, the DRC, and the import market is dominated by one country: China.”

The document also highlights that China imported almost 90% of its cobalt from the DRC, worth a total of $2.17 billion. Once imported, the metal is further refined and integrated into battery chemicals.

“The line of ownership is clear in the supply chain at this stage, as China owns or finances most cobalt mines in the DRC, and China imports almost 90% of its cobalt from the DRC,” the document points out. “Chinese companies use cobalt tainted with child labor to manufacture battery components, such as cathodes, which in turn are used to make lithium-ion batteries. Sources estimate that at least half of all cobalt ends up in rechargeable batteries. This creates enormous labor risks for the electronics industry, electric vehicle supply chains, and other goods that depend on lithium-ion batteries.”

The report also urges companies to track the cobalt supply chain by acquiring knowledge of trade data, supplier information, transport routes, and processing steps.

Demanding such information and conducting their own research, will give companies “fewer excuses—such as the distance between raw materials and the finished product or supply chain complexity—to point to their lack of accountability in determining if a supply chain is tainted with child labor or forced labor,” the document states.