Five Questions, Five Answers: Is there Forced Labor in Your Supply Chain? Prevent Costly Import Detentions at the Border
Combatting forced labor is growing from aspiration of company boards to a mission-critical focus impacting day-to-day operations. Companies with global footprints are not alone in witnessing acute compliance and reputational...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
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
In recent years, the global spotlight has illuminated the grave concerns surrounding human rights violations within China's Xinjiang region, particularly those impacting the Uyghur population. The Uyghur 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
Many have viewed corporate commitments to ESG as largely performative measures amidst toothless compliance frameworks. But this has been changing and we expect that change to continue. One example arises out of the “S” in...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
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
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
In recent months, there has been much attention focused on Beijing’s labor policies and practices toward the Uyghur Muslim population and other minority groups in China. Given that the western Xinjiang region is responsible...more
On December 7, 2020, U.S. Customs and Border Protection (CBP) modified an existing Withhold Release Order (WRO) on bone black produced in Brazil by Bonechar Carvão Ativado do Brasil Ltda (Bonechar). As a result of this...more
Additional Restrictions on Exports to Cuba - On October 15, 2019, the Department of Commerce (DOC) amended the Export Administration Regulation (EAR) to further restrict the export and reexport of items to Cuba. The...more