MTW’s Comment on the Operation of the USMCA and recommendations to improve protections for workers

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Comment in response to FR Doc. 2025–18010 Request for Public Comments and Notice of Public Hearing Relating to the Operation of the Agreement Between the United States of America, the United Mexican States, and Canada; Docket No. USTR-2025-0004

Dear Mr. Watson,

Migration that Works writes to comment on the Operation of the United States – Mexico – Canada Agreement (“USMCA”) and recommend changes to improve protections for workers under the USMCA.

Migration that Works is a coalition of labor, migration, civil rights, and anti-trafficking organizations and academics advancing a labor migration model that respects the human rights of workers, families, and communities, and reflects their voices and experiences. Founded in 2011 as the International Labor Recruitment Working Group (ILRWG), Migration that Works aims to strategically address worker rights abuses across industries and visa categories.[1]

Migration that Works joins workers in supporting and advancing an ethical labor migration model in the legal and regulatory frameworks in the United States.[2] Our model for labor migration shifts control over the labor migration process from employers to workers, elevates labor standards for all workers, responds to established labor market needs, respects family unity, ensures equity and access to justice, and affords migrant workers an accessible pathway to citizenship. An ethical labor migration model would robustly protect all workers, while also ensuring that law-abiding employers are not undercut by low-road employers.

Migration that Works applauds the inclusion of a labor chapter in the USMCA and its explicit recognition of key worker rights but urges the U.S. government to update its laws to enforce protections in the treaty.

  1. Background

Migration that Works coalition members are experts on the temporary work nonimmigrant visa programs (sometimes referred to as “guestworker” programs) in the United States. Members have extensively analyzed regulations, enforcement frameworks, and publicly available data on these programs. Several coalition members also have regular, direct contact with workers in temporary visa programs, either through hotline or intake calls, through representation for administrative or legal proceedings in employment matters, or through union membership. Migration that Works’ collective proximity to migrant workers and analysis of the temporary visa programs have led us to conclude that recruitment abuses are still far too common across the programs, and the current schema of regulations and lax enforcement do not adequately protect migrant workers from low-road employers looking to game the system and exploit their labor.

Employers in high-wage and low-wage industries hire people abroad to work through temporary work visa programs. Temporary work visas include: A-3, B-1, F-1, G-5, H-1B, H-1C, H-2A, H-2B, J-1, L, O-1, P-3 and TN, each with its own rules and requirements. Unfortunately, these programs are rife with flaws that enable worker abuse. Common issues in these programs include recruitment fraud, rampant discrimination, wage theft, and labor trafficking. These patterns of abuse are common across visa categories.

Temporary work visa programs are not transparent. During recruitment, workers have limited access to information; they often do not know how to verify whether they are dealing with legitimate agents or recruiters of prospective employers, or swindlers looking to charge them recruitment fees for an illusory employment opportunity. Even when prospective workers communicate with legitimate employers, they often do not receive complete information about the terms and conditions of employment in the U.S. This information asymmetry hampers workers’ ability to make an informed decision about a job offer, and at worst, leads them right into an abusive workplace.

Chapter 23 of the USMCA, the labor chapter, is a critical step forward in protecting workers of the three countries from labor exploitation and trafficking. Our coalition chair, Centro de los Derechos del Migrante, Inc. (“CDM”), is a binational worker rights organization with a 20-year history of working alongside migrant and immigrant families to ensure that borders are not a barrier to justice. CDM had previously called for a stronger labor enforcement mechanism in USMCA’s predecessor North American Free Trade Agreement’s (“NAFTA”) labor side accord North American Agreement on Labor Cooperation (“NAALC”).[3] Specifically, CDM urged the U.S. Trade Representative’s Office to develop a process by which migrant workers could complain and access justice with a specific and prompt timeline for response, and urged each country to update their own laws and regulations to protect workers rights.

The USMCA includes crucial protections for workers in all three countries. USMCA’s Chapter 23 on Labor recognizes and articulates a commitment to the workers’ rights, including: freedom of association and right to collective bargaining, elimination of forced labor, abolition of child labor, and elimination of discrimination,. Chapter 23 also states a commitment to ensure that each country’s legal system upholds acceptable work conditions.[4] Under USMCA’s Chapter 23, the signing Parties also commit to enforce labor laws by taking specific steps, including investigating alleged violations, compelling employers to keep records, initiating proceedings for investigation and appropriate sanctions in the event of a violation of labor laws, and implementing sanctions or remedies for noncompliance with labor laws.[5] Chapter 23 also explicitly recognizes that migrant workers’ rights are to be protected under the Parties’s labor laws, regardless of their citizenship status.

For the USMCA’s protections to be effective, labor protections for workers must be well-enforced by each signing Party. While Article 23.5 explicitly outlines steps each Party can take to robustly enforce their labor laws to protect workers and, in the U.S., the Department of Labor (“DOL”) is tasked with enforcing federal U.S. labor laws, DOL is vastly under-resourced. The Trump Administration asked to reduce DOL’s budget for Fiscal Year 2026 by almost 35% of its Fiscal Year 2025 budget.[6] The Wage and Hour Division (“WHD”) of the DOL typically conducts investigations involving potential violations of federal wage and hour laws, but in recent decades, the U.S. government has not sufficiently funded the DOL, resulting in fewer investigations into labor violations.[7] The lack of investigations has severe implications for the enforcement of wage and hour laws in industries that rely on migrant workers. For example, a recent report showed that as many as 70% of farm employers investigated by the DOL had violated employment laws.[8] Without real enforcement, the U.S. falls short of realizing existing protections for migrant workers.

U.S. laws also fail to protect migrant workers in the U.S. from workplace abuse. Specifically, the Migrant and Seasonal Agricultural Worker Protection Act (“AWPA”) explicitly excludes H-2A temporary agricultural workers from its protections.[9] In addition, the U.S. fails to uphold freedom of association and collective bargaining rights for migrant and U.S.-based farmworkers under the National Labor Relations Act (“NLRA”), which excludes agricultural and domestic laborers. Compounding the exclusion of migrant workers from major employment laws, many workers with temporary work visas are barred from receiving support from federal Legal Services Corporation-funded programs. This means that these migrant workers, most of whom have limited resources and work in rural areas, have few or no options for accessible legal representation when faced with unjust or illegal working conditions. Congress should end these exclusions to ensure that migrant workers can enforce their rights.

The United States also needs to develop a comprehensive strategy to protect workers from gender discrimination, as it committed to in the USMCA. Migrant workers currently face flagrant discrimination in recruitment[10] and employment in the United States. Title VII protections for migrant workers are underenforced, and workers face many barriers, including language and technology, from being able to adequately access the Equal Employment Opportunity Commission’s complaint system.

Finally, while we support the USMCA Parties’ explicit commitment to end forced labor, the U.S. must end the economic coercion migrant workers face during recruitment for employment opportunities in the U.S. through the temporary work visa programs. Unscrupulous recruiters charge illegal fees and engage in other coercive practices, such as forcing workers to sign promissory notes to obtain a job through temporary visa programs. Such practices force migrant workers to accrue debt and leave them at higher risk for human trafficking.

  1. The United States must extend the Migrant and Seasonal Agricultural Worker Protection Act (“AWPA”) to cover H-2A workers.

To comply with its obligations under Article 23.8 to protect all migrant workers, the U.S. needs to ensure that its labor laws adequately cover migrant workers. For example, the Migrant and Seasonal Agricultural Worker Protection Act (AWPA) unfairly excludes H-2A workers. Congress should end this exclusion.

The H-2A work visa program allows employers to hire migrant workers to perform agricultural work in the United States on a temporary or seasonal basis. To participate in the H-2A program and employ H-2A workers, employers must certify that: 1) too few U.S. workers are able, willing, and qualified to fill the positions, and available to perform the work at the place and time needed, and 2) working conditions and wages of U.S. workers similarly employed will not be adversely affected by the hiring of H-2A workers.[11] In 2022, H-2A workers made up about 17%  of crop workers of the U.S. agricultural workforce.[12] Since 2020, when the USMCA treaty was signed, issuance of H-2A visas has increased by over 100,000 visas.[13] The exponential growth of the program makes it all the more necessary for the U.S. to ensure that migrant workers are protected from labor exploitation to the fullest extent of labor laws and regulations.

Unfortunately, the H-2A program design makes it difficult to ensure that all workers, including H-2A workers and those in corresponding employment, are protected as intended. CDM has documented the structural flaws that migrant workers face in the H-2A program, chief among them the fact that workers’ H-2A visas, and their ability to stay in the U.S., are tied to their employer.[14] This fact alone dissuades H-2A workers from complaining about workplace conditions, because they understand that their employer has the power to fire them (typically causing them to lose their authorization to stay in the United States), or choose not to hire them the following season. Both of these are undesirable scenarios for most migrant workers, especially if they are still paying off debt accrued in the process of coming to the U.S. to work, or if they are their family’s primary breadwinner. If H-2A workers are fired, they must leave the United States within 60 days or risk accruing unlawful presence, which can result in lasting immigration-related consequences that could prevent them from returning to the U.S. in the future.

The Seasonal and Temporary Agricultural Worker Protection Act (“AWPA”) provides additional protections for farmworkers in the United States. The AWPA provides safeguards around employer use of foreign labor contractors; requires employers to adhere to federal and state health and safety laws for worker housing and transportation; and provides specific wage-related requirements, including the requirement to pay workers’ wages when due and provide written, itemized earnings statements. The AWPA also includes important disclosure requirements so that farmworkers have an opportunity to see the terms and conditions of their prospective employment, as well as other recordkeeping requirements to ensure employers preserve information about wages paid to workers.[15] These additional protections allow farmworkers more transparency about the terms and conditions of employment, and provide access to information that allows workers to keep better track of their earnings and identify wage theft.

Unfortunately, AWPA explicitly excludes H-2A workers from its coverage.[16] This exclusion flies in the face of the USMCA, in which Signing Parties promise to ensure that their labor laws protect all migrant workers, whether they are nationals or not of said Party.[17] The United States needs to strike the language that excludes H-2A workers, thereby extending AWPA’s protections to this crucial group of workers.[18]

  1. The United States must extend the National Labor Relations Act (“NLRA”) and Fair Labor Standards Act (“FLSA”) to cover all agricultural and domestic workers.

Article 23.3 of the (USMCA) establishes that all Signing Parties must ensure that their laws, regulations, and practices preserve certain rights under the International Labour Organization Declaration on Fundamental Principles and Rights at Work. This provision incorporates into the USMCA the core labor rights recognized in the 1998 ILO Declaration on Fundamental Principles and Rights at Work (“ILO Declaration”), including freedom of association and right to collective bargaining.[19]

Under Section 2(3) of the National Labor Relations Act (NLRA), agricultural and domestic workers are categorically excluded from the definition of “employee”, thereby denying them access to the processes of union recognition, collective bargaining, and protection against anti-union retaliation.[20] The Fair Labor Standards Act (“FLSA”) further marginalizes this workforce by excluding many farmworkers and domestic workers from overtime pay and, in some cases, from minimum wage coverage.[21]

These legal exclusions in the NLRA and FLSA disproportionately affect low-income and transnational workers, most of whom are members of racial minorities in the United States and many of whom are recruited under conditions of economic coercion and labor in sectors with minimal regulatory oversight. The structure of these laws not only undermines international labor standards, it codifies a racialized hierarchy of labor rights in direct tension with the equality guarantees in Article 23.3 of the USMCA.

The denial of collective bargaining and minimum wage rights to agricultural and domestic workers in the United States is not a loophole; it is a policy. It is a legal structure that has persisted across administrations, serving the economic interests of agribusiness and perpetuating systems of racialized labor subordination. But it is also a breach of the United States’ obligations under the USMCA. Given that recent figures place about 68% of U.S. farmworkers as foreign-born[22] and domestic workers are twice as likely as other U.S. workers to be foreign- born,[23] the impact of exclusion of farmworkers and domestic workers from NLRA and FLSA protections disproportionately affects migrant and immigrant workers.

If the USMCA is to be a meaningful framework for labor rights, then the exclusion of farmworkers and domestic workers, especially migrant farmworkers and domestic workers, must be addressed as a core violation of the agreement. Minimum wage protections and freedom of association and collective bargaining are not abstract ideals; they are tools for dignity, equity, and justice. Without them, there is no path forward. To bring its laws and practices into compliance with the USMCA, the United States must amend the NLRA to eliminate the agricultural exclusion, and specifically strike the language “but shall not include any individual employed as an agricultural laborer, or in the domestic service of any family or person at his home” from the employee definition.[24] In eliminating this language, the NLRA will be brought into compliance with the USMCA and guarantee organizing and collective bargaining rights for all farmworkers. Likewise, the United States must strike the language excluding agricultural and domestic laborers from the FLSA in subsections 6 and 15 of 29 U.S. Code § 213(a).

  1. The United States should extend Legal Services Corporation eligibility to workers in all temporary work visa categories

The Legal Services Corporation (“LSC”) is the largest not-for-profit civil legal aid organization in the U.S., created by the Legal Services Corporation Act. It is designed to provide free, high-quality legal services in noncriminal proceedings to low-income individuals.[25] LSC-funded legal aid programs are often the only resource low-income people in the U.S. have to obtain information or representation to resolve housing, consumer, family, and employment matters, among others. Those eligible for LSC-funded resources include “any person financially unable to afford legal assistance.”[26]

Workers with temporary work visas are arbitrarily excluded from accessing LSC-funded resources, with exceptions for those with H-2A visas, those working specifically in forestry with an H-2B visa, and victims of certain crimes. These exclusions severely limit migrant workers’ ability to access justice and enjoy equal protection of labor laws in the U.S. Article 23.8 of the USMCA requires Parties to ensure that “migrant workers are protected under its labor laws, whether they are nationals or non-nationals of the Party.” The U.S. Congress should direct the Legal Services Corporation Board of Directors to expand benefits to all migrant workers with labor and employment issues, regardless of their nonimmigrant visa, or whether they are nationals or non-nationals.

  1. The United States must make reforms to uphold its commitment under the USMCA Article 23.3 to eliminate “discrimination in respect of employment and occupation”

Gender discrimination continues to be rampant in the temporary work visa programs. In the H-2A program alone, women face barriers the moment they interface with recruiters in their home countries. Unscrupulous recruiters and their agents blatantly advertise employment opportunities by specifying their desired demographics, usually excluding women.[27] The exclusion of women from H-2A opportunities carries through to later stages of recruitment and hiring. In Ripe for Reform, a report by CDM detailing systemic flaws in the H-2A program, 86% of women seeking employment with an H-2A visa reported that they were either not hired or offered less favorable pay than men.[28] As CDM’s 2019 USMCA complaint on behalf of migrant women highlighted, only 3% of H-2A visas were issued to women workers. A recent Government Accountability Office (“GAO”) report shows that the gender demographic breakdown in the H-2A program has not changed in the years 2018 through 2023 – women continue to make up only 3% of the H-2A workforce.[29]

Though women are generally better represented in other temporary work visa programs, such as the H-2B program, employers and recruiters hire them into lower-paying, often gendered, positions, where they do not enjoy the H-2A program benefits of free housing and transportation.[30] In a 2018 survey of women participating in H-1B, H-2A, H-2B, J-1 and TN visa programs, 48% of the workers surveyed reported receiving earnings below the federal minimum wage.[31] Women crab pickers in the Eastern Shore of Maryland, who work with H-2B visas, reported being offered positions with lower pay and less job flexibility than their male counterparts. The crab pickers also face another form of wage discrimination, being paid by the pound instead of an hourly rate.[32]

  1. Data transparency is needed to understand the scope of the problem and allow prospective workers to verify job opportunities and review terms and conditions of employment.

While there is some publicly available information about the H-2 programs, there is very little publicly available data about the TN, J-1, and other visa programs. The U.S. government should direct the departments involved in the certifying petitions and processing visas for the temporary work visa programs (Department of Labor, Department of Homeland Security, and Department of State, hereinafter “the Departments”) to release information publicly for the benefit of migrant workers, their advocates, and the general public.

The  Departments need to release demographic data on migrant workers hired (and those considered for employment opportunities through these programs) disaggregated by gender, age, and national origin. The data should include both people who apply to the programs and those who are ultimately hired through these programs. Similarly, the Departments should publicly disclose the employers, recruiters, and agents involved in each temporary visa program to further transparency and ensure accountability. For each employer, recruiter, and agent, data should include: name and address, type(s) of visas petitioned for, visas certified/approved for, years the employer obtained said visas, visa workers’ position(s), visa workers’ wage or salary, and dates of employment. This information will help the U.S. government, workers, and advocates to monitor gender discrimination trends and identify areas for legislative, regulatory, or other action to protect migrant workers from discrimination, as required under the USMCA. 

The lack of transparency in recruitment facilitates fraud and labor trafficking. As discussed, many prospective migrant workers interface with unscrupulous recruiters or individuals claiming to be recruiters. Some recruiters promise job opportunities in the U.S. in exchange for steep illegal recruitment fees. Many engage in discrimination. The U.S. government can protect workers from recruitment fraud and abuse by creating an accessible database, available in migrant workers’ languages, that allows workers to verify recruiter information and job opportunities, including pay and other related terms and conditions of employment, so that workers can make an informed decision about whether or not to accept an employment opportunity. Workers should also have access to information on the status of their visas, so they can verify that they truly have an application being processed. This information is particularly important when a worker leaves an abusive H-2 employer and seeks employment through another H-2 employer. If an employer promises to hire a worker after they leave their original employer, but does not file the required paperwork, the worker can lose their permission to stay in the United States and face immigration-related consequences.

  1. U.S. labor agencies should take practical steps in proactively enforcing existing laws and regulations governing the H-2 and other temporary visa programs.

The U.S. Department of Labor’s (DOL) Wage and Hour Division (WHD) should create a cross-agency enforcement initiative to identify and address labor violations generally in the temporary work visa programs, and address other important issues such as discrimination. WHD should coordinate within the DOL and across agencies, including the Equal Employment Opportunity Commission (EEOC), as well as the Department of State and Department of Homeland Security.  Proactive measures the DOL and other agencies should take include:

  • Audits of payroll records of employers participating in the temporary work visa programs to ensure compliance with minimum and prevailing wage laws as well as rules for deductions, reimbursable expenses, and illegal recruitment fees;
  • Training for DOL frontline staff such as Wage and Hour Investigators to detect indicia of sex-based discrimination (e.g., pay disparities between men and women) and a formal process for referring matters between the WHD and EEOC;
  • Identifying, recommending, and implementing debarment of employers who work with recruiters that routinely violate migrant workers’ rights (and making that information available publicly through a worker-facing database, such as the one described earlier in the comment);
  • Coordinating closely with Employment and Training Administration to engage in careful vetting of temporary employment certification applications (or their equivalent for the different temporary visa programs) and certifying contracts for H-2 and other temporary work visa programs, and prohibit employers and recruiters from using contracts containing breach fees or other liquidated damages clauses that coerce workers into staying in exploitative employment.

The EEOC, the agency that addresses discrimination in employment, can take some practical steps to make the administrative complaint process more accessible to migrant workers. Steps could include:

  • Creating an enforcement initiative targeting discrimination in temporary work visa programs;
  • Hiring employees who speak Spanish, indigenous languages, and other common languages represented in the temporary work visa programs to answer EEOC’s telephonic hotline, and enhancing the hotline with free international calling for migrant workers who are outside of the U.S.;
  • Translating and making available the EEOC website and charge form in multiple languages, including Spanish and indigenous languages (where possible);
  • Providing supporting documentation to the Department of Homeland Security to facilitate migrant workers’ ability to travel to the U.S. to participate in litigation or other administrative proceedings involving discrimination.

The DOL regularly engages in employer education and makes information about employers’ legal obligations available on their website.[33] We urge the DOL to provide employers that hire through the temporary work visa programs information and training about their obligations under Title VII of the Civil Rights Act of 1964. The DOL should update forms for labor certification, such as ETA 790A or ETA 9142 Appendix B, with assurances that require employers to affirm they will abide by all local, state, and federal anti-discrimination laws, as well as any other applicable employment laws. Finally, the DOL should direct the Office of Foreign Labor Certification to build a similar process into their registration process, so that employers will have to affirm that they will abide by all local, state, and federal anti-discrimination and employment laws.

While the DOL has developed multilingual, audiovisual educational materials[34]  to educate workers on their labor and employment rights, it must do more to educate the hundreds of thousands of migrant workers who work in the U.S. The DOL can enhance its reach by contracting with civil society organizations to conduct worker outreach, both in the U.S. and abroad, to reach people before, during, and after their employment.

  1. Conclusion

The U.S. must preserve Chapter 23 of the USMCA during renegotiations in 2026. Trade would not exist without the labor that workers provide in all three countries. The U.S. must  preserve and strengthen workers’ rights. The U.S. can and must do more to protect migrant workers’ rights and ensure all migrant workers have meaningful access to justice.

Sincerely,

Migration that Works

[1] For more information on Migration that Works, visit https://migrationthatworks.org/. To view Migration that Works’ reports, visit https://migrationthatworks.org/reports/. 

[2] Exhibit A, See Migration that Works, Proposal for an Alternative Model for Labor Migration (2020), https://migrationthatworks.org/wp-content/uploads/2025/10/alternative-model-for-labor-migration-updated-2025.pdf

[3] Exhibit B, Centro de los Derechos del Migrante, Inc., Comment on Proposed Rule, “Negotiating Objectives Regarding Modernization of the North American Free Trade Agreement with Canada and Mexico” (May 23, 2017), https://www.regulations.gov/comment/USTR-2017-0006-1387.

[4] Exhibit C, United States–Mexico–Canada Agreement at Chapter 23 Article 23.3, Office of the U.S. Trade Representative, https://ustr.gov/trade-agreements/free-trade-agreements/united-states-mexico-canada-agreement/agreement-between [hereinafter USMCA]. See also United States–Mexico–Canada Agreement Implementation Act, Pub. L. No. 116-113, 134 Stat. 11 (2020).

[5] Id. at 23-4.

[6] Exhibit D, Letter from Russell T. Vought, Director of Office of Management and Budget to Susan Collins, U.S. Senator (May 2, 2025), https://www.whitehouse.gov/wp-content/uploads/2025/05/Fiscal-Year-2026-Discretionary-Budget-Request.pdf

[7] Exhibit E, Daniel Costa and Philip Martin, Record-low number of federal investigations of farms in 2022 (2023), https://www.epi.org/publication/record-low-farm-investigations/

[8] Id.

[9] 29 U.S.C. §§ 1802

[10] Exhibit F, recent H-2A job advertisement.

[11] 8 U.S.C.  §§ (a)(15)(H)(ii), 1188(a)(1); 20 C.F.R. § 655.

[12] Exhibit G, Daniel Costa, How many farmworkers are employed in the U.S. (2023), https://www.epi.org/blog/how-many-farmworkers-are-employed-in-the-united-states/

[13] Exhibit H, Department of State, Nonimmigrant Visas Issued by Classification, available at https://travel.state.gov/content/dam/visas/Statistics/AnnualReports/FY2024AnnualReport/Table%20XVA.pdf

[14] Exhibit I, CDM, Ripe for Reform: Abuse of Agricultural Workers in the H-2A Program (2020), https://cdmigrante.org/wp-content/uploads/2020/04/Ripe-for-Reform.pdf.

[15] Exhibit J, DOL, Fact Sheet #49: The Migrant and Seasonal Agricultural Worker Protection Act (2008), https://www.dol.gov/agencies/whd/fact-sheets/49-mspa

[16] 29 U.S.C. § 1802(8)(B)(ii).

[17] USMCA supra note 4, at Chapter 23 Article 23.

[18] Specifically suggesting to strike “any temporary nonimmigrant alien who is authorized to work in agricultural employment in the United States under sections 101(a)(15)(H)(ii)(a) and 214(c) of the Immigration and Nationality Act [8 USCS §§1101 (a)(15)(H)(ii)(a), 1184(c)

[19] USMCA supra note 4, at Chapter 23 Article 23.3

[20] 29 U.S.C. § 152(3).

[21] 29 U.S.C. §§ 213(a)(6) and (15).

[22] USDA, “Legal status of hired crop farmworkers, fiscal 1991-2022,” https://www.ers.usda.gov/data-products/chart-gallery/chart-detail?chartId=63466

[23] Exhibit K, Asha Banerjee, Katherine deCourcy, Kyle K. Moore, and Julia Wolfe, Domestic Workers Chartbook 2022 (2022), https://www.epi.org/publication/domestic-workers-chartbook-2022/ 

[24] Supra, note 20.

[25] 42 U.S.C. § 2996b(a).

[26] 42 U.S.C. § 2996a(3).

[27] Supra note 10.

[28] CDM, supra note 11, at 7.

[29] Exhibit L, GAO, H-2A Visa Program: Agencies Should Take Additional Steps to Improve Oversight and Enforcement (2024), https://www.gao.gov/assets/gao-25-106389.pdf.

[30] Exhibit M, CDM, Engendering Exploitation: Gender Inequality in U.S. Labor Migration Programs (2018), https://cdmigrante.org/wp-content/uploads/2018/01/Engendered-Exploitation.pdf

[31] Id., at 7.

[32] Exhibit N, CDM, Breaking the Shell: How Maryland’s Crab Pickers Continue to be Picked Apart (2020), https://cdmigrante.org/wp-content/uploads/2020/09/Breaking-The-Shell.pdf.

[33] U.S. DOL WHD, “Resources for Employers,” https://www.dol.gov/agencies/whd/employers

[34] U.S. DOL, “MigrantWorker.gov,” https://www.dol.gov/general/migrantworker

Submitted through: https://comments.ustr.gov/s/submit-new-comment?docketNumber=USTR-2025-0004

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