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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
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
On 22 December 2023, the Biden administration issued Executive Order 14114, “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (EO 14114), thereby amending EOs 14024 and 14068. The new EO...more
What You Need to Know - In October 2023, the Department of Treasury’s Office of Foreign Asset Control (OFAC) enacted multiple sanctions targeting the supply chain of fentanyl and other illicit drugs. In addition to...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 United States has added yet another customs tool in its ongoing work against forced labor in supply chains. Following on the heels of the Uyghur Forced Labor Prevention Act ("UFLPA") and an uptick in Withhold Release...more
After several years of review by U.S. Customs and Border Protection (“CBP”), the Customs Broker community, and the Commercial Customs Operations Advisory Council, CBP unveiled the new Customs Broker Regulations under 19...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 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
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
On June 13, 2022, the U.S. Department of Homeland Security’s Customs and Border Protection (“CBP”) published guidance for importers regarding compliance requirements under the Uyghur Forced Labor Prevention Act (“UFLPA”),...more
On December 23, 2021, President Biden signed the bipartisan Uyghur Forced Labor Prevention Act (UFLPA or the “Act”), Pub. L. No. 117-78, which will ban the importation of all goods sourced from the People’s Republic of...more
President Joe Biden signed the Uyghur Forced Labor Prevention Act (H.R. 6256) into law on December 23, 2021. The act seeks to ensure that goods produced using forced labor do not enter the United States. U.S. Customs and...more
The U.S. Congress has passed a landmark piece of legislation that prohibits the importation of goods from an entire region due to the high risk of severe forced labor abuses there. The legislation – the Uyghur Forced Labor...more
The long-debated Uyghur Forced Labor Prevention Act (UFLPA) has now passed both chambers of Congress with strong bipartisan support, and President Biden is expected to sign the UFLPA into law on or before December 30, 2021....more
The US Senate and House of Representatives have both passed HR 6256, the bicameral, bipartisan Uyghur Forced Labor Prevention Act, with the Senate approving the measure by unanimous consent on December 16. ...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
On January 1, 2021, the Conflict Minerals Regulation (EU Regulation 2017/821) came into full force across the EU. This new law aims to ensure that importers of certain materials originating from conflict-affected and...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
On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) on cotton and tomato products produced by entities operating in Xinjiang, China. The order is based on information that...more
The EU has finally adopted new transparency rules regarding so-called conflicts minerals being imported into the EU. This follows a series of policy initiatives from the European Commission to drive for greater transparency...more
The new EU rules on conflict minerals impose strict due diligence requirements on EU importers of gold, tin, tungsten and tantalum. On 19 May 2017 Regulation 2017/821, which sets out supply chain due diligence obligations for...more