Insight

Cracking Down or Falling Behind?

Pennsylvania’s Tougher Child Labor Penalties Amid a National Rollback

Unqualified teen worker uses dangerous machinery
BD

Bryan Driscoll

June 20, 2025 05:00 AM

Child labor laws are diverging sharply across the United States. In Pennsylvania, lawmakers have taken a clear stance by attempting to increase penalties for violations—a move that contrasts sharply with recent efforts in states like Florida to relax long-standing work restrictions for teens.

At the federal level, the Trump administration recently eliminated funding for international child labor enforcement, stripping oversight from a system already under pressure. The result is a legal and political split: while some jurisdictions crack down on child labor violations, others are rolling back protections that have stood for decades.

For businesses, attorneys, and compliance professionals, that split presents growing uncertainty. Navigating the evolving patchwork of laws—especially when operating across state lines or managing global supply chains—requires more proactive legal guidance than ever before.

Pennsylvania Moves to Strengthen Child Labor Enforcement

In March 2025, the Pennsylvania House of Representatives passed House Bill 118, which would double the fines imposed on employers who violate the state’s Child Labor Act. Introduced by Representative Regina Young, the bill raises the maximum penalty for a first offense from $500 to $1,000, and for repeat violations from $1,500 to $3,000. The legislation now moves to the Senate for consideration.

The bill is narrow in scope—it doesn’t alter the underlying restrictions on youth employment—but it sends a clear message about enforcement. For years, relatively low penalties have allowed some employers to view child labor violations as manageable business expenses. HB 118 aims to shift that calculus by raising the stakes, particularly for repeat offenders.

Supporters of the bill framed it as a necessary response to an increase in violations, both nationally and at the state level. Representative Young emphasized the importance of deterrence, especially in industries where minors are frequently employed in fast-paced, under-supervised environments. The bill passed with bipartisan support, but not without pushback. Republican lawmakers argued the changes would create unnecessary burdens for employers already struggling with staffing shortages.

But critics argue this overlooks the core issue. The bill simply raises the price for employers who choose to disregard existing protections. In doing so, it acknowledges the imbalance between enforcement capacity and employer behavior. Pennsylvania’s Department of Labor & Industry has been tasked with overseeing compliance across a wide range of industries, and increased penalties can serve as both a deterrent and a justification for enhanced oversight.

The business opposition also glosses over the legal risks employers already face. Fines are only one part of the equation. Violations of child labor laws can lead to public investigations, civil liability, and in some cases, criminal penalties. When enforcement gains momentum at the state level, plaintiff-side attorneys and federal regulators tend to take notice. For employers with multi-state operations or federal contracts, the reputational risk alone can far outweigh the cost of compliance.

The proposed changes in HB 118 align Pennsylvania with a small group of states moving to strengthen child labor protections while other states move in the opposite direction. Reports of underage workers in hazardous roles—from meatpacking plants to manufacturing floors—have prompted federal investigations and widespread media attention.

In that context, Pennsylvania’s move is both timely and legally significant. If the Senate passes the bill and it is signed into law, it would give regulators greater leverage in holding violators accountable, while also signaling to employers that compliance isn’t optional.

For lawyers advising clients in Pennsylvania, the message is clear: now is the time to assess internal compliance programs. Employers should review hiring practices, verify age documentation, ensure minor work permits are in place, and confirm that scheduling software flags applicable hour restrictions.

These are not abstract risks. They are quantifiable liabilities that—if HB 118 becomes law—will carry a higher price tag.

Florida’s Push to Loosen Child Labor Protections

While Pennsylvania moves to increase accountability for child labor violations, Florida is taking the opposite approach. In March 2025, the state legislature advanced Senate Bill 918, a measure that would roll back longstanding protections for 16- and 17-year-old workers. The bill removes restrictions on how many hours minors can work during the school year and allows them to take jobs that were previously off-limits due to safety concerns.

Supporters of the legislation frame it as a modernization effort. They argue that current labor laws are outdated and overly restrictive, preventing teenagers from gaining valuable work experience or contributing to their families’ incomes. But critics, including labor advocates and child welfare organizations, see it as part of a broader trend of deregulation that puts young workers at risk—especially in industries with a history of exploitation.

The bill’s language mirrors proposals introduced in other conservative-led states. Florida’s move follows similar efforts in Arkansas and Iowa, where legislatures have already passed bills expanding the number of hours minors can work and reducing employer liability for youth employment violations. These changes often come under the banner of workforce development or economic freedom, but the result is the same: less oversight, fewer safeguards, and more legal ambiguity.

From a compliance perspective, this introduces new complexity. Federal law—specifically the Fair Labor Standards Act (FLSA)—still imposes limits on youth employment, including maximum work hours and bans on certain hazardous occupations. When state laws are weakened, the burden shifts to employers to ensure they’re still aligned with federal rules. That exposes businesses, particularly those without legal counsel, to federal violations despite meeting state rules.

This tension between state and federal law also creates practical enforcement challenges. Agencies tasked with oversight are already stretched thin, and when legal standards vary across jurisdictions, enforcement often falls through the cracks. The result is a system where the law on paper diverges sharply from the reality on the ground—and where violations are more likely to go unnoticed until they escalate into litigation.

For attorneys representing employers in Florida, SB 918 introduces genuine legal uncertainty. The bill’s vague language around acceptable work hours and job types could expose companies to greater liability, especially if they employ minors in multi-location roles or operate in highly regulated industries like construction or hospitality.

The bill’s rapid progress also raises questions about what comes next. If signed into law, SB 918 could open the door to broader revisions of Florida’s child labor code, including further exemptions for specific industries or job classifications. And once those precedents are set, they’re often replicated in other states. Already, similar proposals are being floated in state legislatures across the South and Midwest.

Unlike Pennsylvania, which is reinforcing its labor protections through deterrence, Florida is gambling on deregulation as a solution to labor shortages. For companies operating in both states—or anywhere in between—the only safe move is caution. Compliance is no longer about keeping up with federal standards alone. It's about anticipating how fast the rules can change, and what happens when they do.

The International Pullback—and What It Means for U.S. Businesses

In late March 2025, the Trump administration quietly eliminated funding for international child labor enforcement programs—cutting roughly $50 million from the Department of Labor’s Bureau of International Labor Affairs (ILAB). For over two decades, these funds have supported global initiatives aimed at preventing child labor in agriculture, mining, manufacturing, and other high-risk sectors. Now, that oversight is gone.

The administration’s justification focused on domestic priorities, arguing that the Labor Department should concentrate solely on U.S. workers. But the decision severs a key link in the country’s longstanding role in combatting child exploitation abroad. It also undercuts compliance systems American companies, especially those with global supply chains, have used to document and mitigate labor risk.

Companies that import goods or contract labor abroad now face a higher burden in proving that their supply chains are free of child labor. Without U.S. funding for audits and cooperative agreements with foreign governments, much of the monitoring infrastructure disappears. That increases the risk of falling afoul of international trade rules, ESG standards, and shareholder disclosure requirements.

Attorneys advising clients in retail, agriculture, textiles, and logistics will need to reevaluate how those clients document their supply chain practices. In the absence of ILAB funding and guidance, businesses may need to turn to third-party auditors or develop internal systems for monitoring and remediation—both of which come at a cost. Perhaps more costly, the reputational damage from failing to do so can be far more expensive than any fine.

This shift comes when global labor conditions are already under increased scrutiny. New reporting mandates—such as the EU’s Corporate Sustainability Due Diligence Directive and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act—require companies to demonstrate that they are taking active steps to prevent labor abuses. The U.S. may not yet have a national equivalent, but for multinational firms and publicly traded companies, the legal obligation doesn’t end at the border.

The rollback also sends a broader message: child labor enforcement is no longer a bipartisan priority. That matters not just for diplomats and trade negotiators, but for corporate legal departments trying to assess risk exposure in emerging markets. If oversight is voluntary and inconsistent, liability becomes harder to anticipate, and easier to overlook.

The Cost of Complacency

Child labor law in the U.S. is no longer moving on a unified track. Pennsylvania is moving to strengthen enforcement. Florida is working to weaken it. And the federal government just walked away from global oversight altogether.

For businesses and attorneys, that means greater complexity, not less. The patchwork of laws, inconsistent enforcement, and political signaling leave plenty of room for liability—and very little for error.

Relying on outdated policies or assuming compliance will sort itself out is no longer an option. The message is the same across all jurisdictions: child labor risk is real, rising, and impossible to ignore.

Headline Image: Adobe stock/ MuhammadMuqeet

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