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Trump administration child labor enforcement shifts toward employer-led compliance

September 2025 federal employment law insider
Authors: 

the editors of FELI

The Trump administration’s Department of Labor (DOL) has adopted a markedly different posture on child labor enforcement compared to its predecessor—favoring employer engagement, state flexibility, and targeted enforcement over broad regulatory expansion. While child labor violations remain a national concern and particular focus for the DOL, particularly in high-risk sectors such as agriculture, food processing, and manufacturing, the current administration has reframed its strategy around voluntary compliance and industry best practices.

From aggressive oversight to strategic intervention

Under the Biden administration, the DOL pursued aggressive enforcement of child labor violations, expanding investigations, increasing civil penalties, and proposing new rulemaking to strengthen recordkeeping and joint employer liability. The Wage and Hour Division (WHD) prioritized systemic audits and high-profile enforcement actions, often in coordination with state labor agencies and the Department of Justice.

By contrast, the Trump administration has rolled out employer-led self-audits and guidance. Employers that proactively identify and correct violations may avoid civil penalties altogether, provided they cooperate with WHD and implement remedial measures. The shift reflects a broader deregulatory pattern across the administration—one that seeks to reduce perceived burdens on businesses while preserving core protections for minors in the workforce.

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