Since the inception of the Uyghur Forced Labor Prevention Act (UFLPA), importers globally have started to become acutely aware of potential forced labor risks hidden beneath intricate supply chains....more
7/25/2024
/ China ,
Corporate Counsel ,
Court of International Trade ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Enforcement ,
Forced Labor ,
Goods or Services ,
Importers ,
Manufacturers ,
NGOs ,
Popular ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
In an unprecedented, but anticipated, move last Friday, the US Department of Homeland Security (DHS) expanded the Uyghur Forced Labor Prevention Act (UFLPA) Entity List with the addition of 26 new Chinese textile companies in...more
Several recent US governmental regulatory actions intended to combat forced labor serve as a reminder to government contractors and importers of their need to conduct appropriate “know your supplier” due diligence to identify...more
8/9/2023
/ Certifications ,
Code of Conduct ,
Customs and Border Protection ,
Department of Defense (DOD) ,
Department of Homeland Security (DHS) ,
DFARS ,
Due Diligence ,
Exports ,
Federal Contractors ,
Forced Labor ,
Importers ,
Interim Rule ,
NDAA ,
NGOs ,
Remediation ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
On October 18, 2022, US Customs and Border Protection (CBP) published the long anticipated final rule for the modernization of Customs broker regulations under 19 CFR part 111.
The rule will go into effect on December 19,...more
US Customs and Border Protection (CBP) UFLPA Operational Guidance for Importers (CBP Guidance) was published on June 13, 2022 to assist importers in preparing for the UFLPA rebuttable presumption that goes into effect on June...more
US Customs and Border Protection (CBP) has issued some guidance relating to its enforcement of the Uyghur Forced Labor Prevention Act (UFLPA) prior to June 21, 2022, the effective date of the rebuttable presumption.
US...more
US importers should participate in the Task Force's comment and hearing process to flag due diligence challenges and formulate the strategy to enforce the import prohibitions.
What to Know -
Effective June 21, 2022, 180...more
1/6/2022
/ China ,
Customs and Border Protection ,
Detention ,
Enforcement ,
Export Administration Regulations (EAR) ,
Forced Labor ,
Human Rights ,
Importers ,
Office of Foreign Assets Control (OFAC) ,
Tariff Act of 1930 ,
Uyghur Forced Labor Prevention Act (UFLPA)
On October 5, 2021, the United States Trade Representative (USTR) announced the Biden Administration’s highly-anticipated China trade policy, including a comment request process that will be used to determine whether Section...more
CBP Adds Second Forced Labor Investigations Branch and DHS Publishes Timeline for Actions -
Importers should be prepared for increased forced labor actions (including new Withhold Release Orders and product import bans)...more
10/1/2021
/ Africa ,
Child Labor ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Due Diligence ,
Forced Labor ,
Importers ,
Latin America ,
Middle East ,
Supply Chain ,
Withhold Release Orders (WROs)
First sale appraisement currently remains a legally viable duty savings avenue, including for transactions with vendors in NMEs.
On March 1, 2021, Judge Thomas J. Aquilino, Jr. of the US Court of International Trade (CIT)...more
Companies in the fashion, luxury, and agricultural spaces should take action in response to the forced labor supply chain due diligence requirements Customs recently announced in connection with withhold release orders (WRO)...more
Just two weeks into CY 2021, US Customs and Border Protection (CBP) is expanding its enforcement efforts against forced labor in China.
This follows months of increasing pressure from labor and human rights groups and...more