U.S. International Trade Commission
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
Enforcement actions by U.S. Customs and Border Protection (CBP) are increasingly more intensive and less lenient than in the past based on our experience. It is not uncommon in today’s regulatory enforcement landscape for...more
The rebuttable presumption of the Uyghur Forced Labor Prevention Act ("UFLPA") took effect on June 21, 2022. As a reminder, under this presumption for purposes of Section 307 of the Tariff Act of 1930, goods produced in the...more
Forced Labor Enforcement Task Force issues required enforcement strategy, including guidance to importers. On June 21, 2022, the key operative provision of the Uyghur Forced Labor Prevention Act (UFLPA) entered into...more
On January 24, 2022, the U.S. Department of Homeland Security (DHS) on behalf of the Forced Labor Enforcement Task Force (FLETF) issued a Notice Seeking Public Comments on Methods to Prevent the Importation of Goods Mined,...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
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
Legislation Will Block Imports Linked to Human Rights Abuses in China On December 16, 2021, Congress passed H.R. 6256, known as the Uyghur Forced Labor Prevention Act (UFLPA). The UFLPA establishes a rebuttable presumption...more
In an anticipated move, the Biden administration escalated its forced labor enforcement efforts on June 24 by announcing the issuance of a new withhold/release order (WRO) that blocks the import of certain polysilicon-based...more
U.S. Customs & Border Protection (CBP) issued a forced labor finding on March 29, 2021 against Top Glove Corporation Bhd. (Top Glove), a Malaysian manufacturer of disposable gloves, a product which has been in high demand...more
Because of the time needed to mark, pack, and ship goods from Hong Kong to the US, it is imperative that importers act quickly to ensure compliance with this new requirement. As reported previously and as a result of the...more
In a decision that highlights the overlap of international trade obligations and False Claims Act (FCA) jurisprudence, a federal judge recently dismissed an FCA suit because the whistleblower’s claims, against an importer of...more