Despite legislation aimed at preventing labor and other human rights abuses in supply chains taking force in major countries including the United Kingdom, United States, Germany, and France, many companies are struggling to comply.

Part of the problem could be differences in the expectations of national legislation, as well as varying sanctions and appetites for enforcement. Germany’s Supply Chain Act, for example, puts the onus on companies to try to prevent labor abuses, rather than necessarily stamp them out altogether. The U.K.’s Modern Slavery Act, meanwhile, only requires firms to report on the steps they are taking to identify and root out incidences of slavery; it is up to other national legislation to punish offenders.

Differences in the level of commitment become apparent when compared to the requirements of the U.S. Uyghur Forced Labor Prevention Act that went into effect in June. Under that legislation, companies should automatically presume goods made either wholly or in part in the Xinjiang region in northwestern China involve forced labor and should be avoided, unless they can prove—without doubt—they were produced ethically and in compliance with the law.