Chapter III introduction on assessing implementation in practice
Of the 42 U.S. retailers and manufacturers of apparel that provided reportable responses to the Department of Labor's voluntary survey, 36 stated that they had adopted some sort of policy prohibiting child labor in overseas production facilities. Those policies take different forms, from formal public codes of conduct to child labor bans written into contracts with foreign producers. Adopting a policy is a positive step; making it effective requires commitment from all interested parties to implement it. This chapter's central objective is to assess the implementation practices of the U.S. apparel importers that have such policies.

Introduction (Chapter III)
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III. Implementation Experiences of Codes of Conduct in the U.S. Apparel Industry
A. Introduction
As has been reported in Chapter II, 36 of the 42 U.S. retailers and manufacturers of apparel which provided reportable responses to the Department of Labor voluntary survey stated that they had adopted some sort of policy prohibiting child labor in overseas production facilities. These policies takes different forms, from formal public codes of conduct to provisions banning the use of child labor in contracts between the foreign producer and the importing U.S. corporation.
The fact that U.S. retailers and manufacturers of apparel have adopted policies against the use of child labor in the production of garments is a positive step toward the objective of eliminating the use of child labor. Clearly, for such policies to be truly effective, there has to be a commitment on the part of all interested parties to implement them. Consequently, a central objective of this study is to assess the implementation practices of U.S. apparel importers that have policies regarding child labor.
Through the voluntary responses to the survey instrument sent out to U.S. manufacturers and retailers of apparel and follow-up phone interviews with respondents, the Department of Labor learned a great deal about the implementation of codes of conduct from the perspective of the U.S. companies that import the garments and originate the codes. Although these companies have generally been cooperative, company officials responding to the inquiries were not always able to provide definitive explanations regarding specific aspects of the implementation of their policies.
To further review the actual implementation of codes of conduct, Department of Labor officials visited six countries where there is extensive production of garments for the U.S. market. This chapter describes the field visits and summarizes their findings regarding transparency, monitoring and enforcement of codes of conduct - the primary elements identified in Chapter II.
This report was developed and provided by the U.S. Labor Department http://www.dol.gov/iLAB/media/reports/iclp/apparel/main.htm
The chapter's evidence comes from two directions. From the importing side, the Department of Labor learned about implementation through companies' voluntary responses to its survey instrument and through follow-up telephone interviews with respondents. From the production side, the field visits described in this chapter tested what those company accounts meant inside actual factories. The two views do not always coincide: company officials responding to the inquiries were not always able to provide definitive explanations of specific aspects of implementation in their own supply chains. That gap — between a policy as described at headquarters and a practice as found in a plant — is the chapter's recurring theme.
The sections that follow take the elements in turn: field visits, child labor findings in the industry, transparency, monitoring and enforcement. Together they answer the question the first two chapters set up — not whether codes exist, but whether they work where garments are sewn.
Thirty-six of the 42 U.S. retailers and manufacturers that provided reportable responses stated they had adopted some sort of policy prohibiting child labor in overseas production facilities.
From formal public codes of conduct to provisions banning child labor written into contracts between the foreign producer and the importing U.S. corporation.
Through companies' voluntary survey responses, follow-up telephone interviews with respondents, and field visits to garment-producing countries.