Five Questions, Five Answers: Is there Forced Labor in Your Supply Chain? Prevent Costly Import Detentions at the Border
On April 10, 2024, U.S. Customs and Border Protection (“CBP”) issued a Withhold Release Order (“WRO”) on a Chinese company, Shanghai Select Safety Products Co., Ltd. (“Shanghai Select”) and its two subsidiaries, Select...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
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
Join Braumiller Law Group Senior Counsel Bruce Leeds for the second presentation in a monthly series regarding Hot Topics in International Trade Compliance Forced Labor/Slave Labor/Uyghur Labor - The latest on human rights...more
In April of this year U.S. Customs & Border Protection (CBP) issued Headquarters Ruling H330077. The ruling was in response to a protest filed by an importer that had a shipment of wearing apparel excluded from entry under...more
On February 23, 2023, U.S. Customs and Border Protection (“CBP”) released new guidance for importers seeking admissibility of goods under the Uyghur Forced Labor Prevention Act (“UFLPA”). The three guidance documents include...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
On Nov. 23 Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) restricting imports of raw sugar and sugar-based products produced in the Dominican Republic by Central Romana Corporation Limited (Central...more
The Uyghur Forced Labor Prevention Act (UFLPA) was signed into law by President Biden on December 23, 2021. It establishes a rebuttable presumption that the importation of goods produced, or manufactured wholly or in part, in...more
This Primer provides introductory guidance to complying with U.S. forced labor laws for importers, and includes an introductory overview to forced labor laws, U.S. Customs and Border Protection’s (CBP) authority to enforce...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
Can you prove the absence of forced labor in your supply chain? As of June 21, 2022, US Customs and Border Protection (CBP) will presume that all goods manufactured in whole or in part in the Xinjiang Uyghur Autonomous Region...more
On December 21, 2021, President Joe Biden signed into law legislation entitled the Uyghur Forced Labor Prevention Act (“UFLPA”), which came into effect on June 21, 2022. In relevant part, the law prohibits certain imports...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
U.S. Customs and Border Protection (CBP) released long-awaited Operational Guidance for Importers (Operational Guidance) on June 13, 2022, to assist importers in preparing for the implementation of the Uyghur Forced Labor...more
The Uyghur Forced Labor Prevention Act (UFLPA), signed into law on December 23, 2021, furthers the United States’ policy of prohibiting the importation of goods made with forced labor. The UFLPA requires Customs and Border...more
On June 13, 2022, U.S. Customs and Border Protection (CBP) released highly anticipated guidance regarding the forthcoming implementation of the Uyghur Forced Labor Prevention Act (UFLPA), which will go into effect on June 21,...more
U.S. Customs and Border Protection (“CBP”) released its first set of guidance relating to the Uyghur Forced Labor Prevention Act (“UFLPA”), which is set to take effect on June 21, 2022. CBP’s guidance takes the form of a...more
In late December 2021, the United States banned imports of disposable gloves produced in Malaysia by manufacturer Brightway Holdings over allegations of forced labor....more
PUBLIC COMMENT PERIOD NOW OPEN - Updates: As previously reported in earlier client alerts, the United States has long prohibited the importation of goods made through forced labor. With respect to China, a...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
Creates A New Forced Labor “Presumption” That Would Prohibit Certain Imports From Entry Into The United States, Among Other Measures, To Address Forced Labor In China - On December 23, 2021, President Biden signed into law...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