by the Dominican Sugar Industry

produced by forced or child labor in violation of international standards pursuant to Section 105(b)(1) of the Trafficking Victims Protection Reauthorization Act Report (TVPRA Report), sugarcane from the Dominican Republic has been included. To the extent that there was ever any basis to include sugarcane from the Dominican Republic on this list, and there was not, there is certainly no basis to continue to do so. Indeed, the Department of Labor has no reasonable basis to believe that sugarcane is produced in the Dominican Republic using child or forced labor in violation of international standards, and continuing to include sugarcane from the Dominican Republic on this list would seem contrary to the Department of Labor’s own procedural guidelines published in 2007 (72 Fed. Reg. 73374) for developing such list. According to the Department of Labor’s (DOL) methodology, the Bureau of International Labor Affairs (ILAB) “conducted an indepth review of available information on exploitive working conditions in the production of goods in 77 countries, based on an initial screening of sources that showed these countries to have a higher incidence of child labor and forced labor. ” 1 The international standards cited by ILAB for developing the definition of child and forced labor for the TVPRA Report are International Labor Organization (ILO) Conventions 138 and 182 on child labor, an