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Prior Disclosure
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In recent years, a multinational focus on preventing forced labor within supply chains has shaped due diligence requirements for companies worldwide. Recent changes to global policies and potential shifts in enforcement...more
The U.S. government has increasingly emphasized the importance of supply chain integrity, particularly in relation to eliminating forced labor. U.S. policymakers are actively passing legislation, including the Uyghur Forced...more
In February 2024, Customs and Border Protection (CBP) began taking a new approach to Uyghur Forced Labor Prevention Act (UFLPA) enforcement—questionnaires. Once again, the solar industry is among the first targets, vanguards...more
On July 9th, the Department of Homeland Security (“DHS”), on behalf of the Forced Labor Enforcement Task Force (“FLETF”), released its 2024 Updates to the Strategy to Prevent the Importation of Goods Mined, Produced, or...more
In the last few years, changes to the United States enforcement stance on the forced labor import ban authorized by 19 U.S.C. § 1307 and passage of the Uyghur Forced Labor Prevention Act (UFLPA) have fundamentally changed the...more
In our previous biweekly update, What Every Multinational Needs to Know About … The Uyghur Forced Labor Prevention Act, Part I, we summarized the UFLPA requirements and the basic expectations that U.S. Customs and Border...more
We have received multiple requests to provide guidance regarding the critically important area of the Uyghur Forced Labor Prevention Act (UFLPA). Because of the recency of the UFLPA, which went into effect on June 21, 2021,...more
The United States Customs and Border Protection (CBP) prioritizes enforcing rules against the use of forced labor and human trafficking. The CBP’s ramped-up enforcement of the Uyghur Forced Labor Prevention Act (UFLPA) is...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
The Act aims to hold fashion retail sellers and manufacturers accountable for their social and environmental impacts through broad supply chain due diligence and public reporting requirements. The fashion industry recognizes...more
In 2020, leaders of Canada, the United States, and Mexico signed the United States Mexico Canada Agreement (USMCA) which, for the first time in a US free trade agreement, includes a ban on imports of products produced using...more
CBP Tech Expo Confirms No Existing “Silver Bullet” Technology and CBP Dashboard Reveals Every Industry Is Subject To Forced Labor Detentions - On March 14-15, 2023, at US Customs and Border Protection’s (CBP) Forced Labor...more
The United States, the European Union, and Germany have recently adopted or proposed new rules requiring enhanced due diligence in supply chains, targeting human rights and environmental issues. This alert examines key...more
US Customs and Border Protection (CBP) recently implemented mandatory forced labor requirements to participate in the Customs Trade Partnership Against Terrorism (CTPAT) and CTPAT Trade Compliance programs. The previously...more
The Strategy provides useful guidance for importers seeking to comply with the provisions of the UFLPA. The Uyghur Forced Labor Prevention Act (UFLPA) was signed into law by President Biden on December 23, 2021, to...more
Key points- •The “rebuttable presumption” of the Uyghur Forced Labor Prevention Act (UFLPA) became effective June 21, 2022. •U.S. Customs and Border Protection (CBP) has issued several releases addressing implementation...more
The Uyghur Forced Labor Prevention Act (the “Uyghur Act”) came into effect on June 21, 2022. As we described previously, the Uyghur Act establishes a rebuttable presumption that goods mined, produced, or manufactured, in...more
The Uyghur Forced Labor Protection Act (UFLPA) applies to all merchandise imported into the United States on or after June 22, 2022. The UFLPA establishes a rebuttable presumption that goods mined, produced, or manufactured...more
As previously discussed in this December Alert, the Uyghur Forced Labor Prevention Act (UFLPA) is effective as of June 21. Customs and Border Protection (Customs) now presumes that all goods produced in Xinjiang, China are...more
With the implementation of the Uyghur Forced Labor Prevention Act, importers of whole or component products from China should begin auditing their supply chains, purchase agreements, and all stages of production. ...more
Today, June 21, the Uyghur Forced Labor Prevention Act (“UFLPA”) comes into effect. It is the latest – and perhaps strongest – tool in the belt of U.S. regulatory and enforcement agencies to combat forced labor....more
The Biden Administration’s interest in reducing the occurrence of forced labor or indentured child labor in the global supply chain, and the parallel goals of corporate social responsibility, are driving increased attention...more
President Biden signed the Uyghur Forced Labor Prevention Act (UFLPA) into law on December 23, 2021. (Click here and here for previous articles on this topic.) On January 24, 2022, the Department of Homeland Security (DHS)...more
Will 2022 Be the Year of Supply Chain Ethics? Effective June 21, 2022, in an effort to address forced labor concerns, U.S. law will broadly prohibit imports of products from China’s Xinjiang Uyghur Autonomous Region...more