Five Questions, Five Answers: Is there Forced Labor in Your Supply Chain? Prevent Costly Import Detentions at the Border
Since the inception of the Uyghur Forced Labor Prevention Act (UFLPA), importers globally have started to become acutely aware of potential forced labor risks hidden beneath intricate supply chains....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
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
US Customs and Border Protection (CBP) has issued some guidance relating to its enforcement of the Uyghur Forced Labor Prevention Act (UFLPA) prior to June 21, 2022, the effective date of the rebuttable presumption. US...more
Critical minerals, which include rare earth minerals, are generally defined as minerals that are important to supply chains, but difficult to mine and ship due to scarcity, geopolitical issues, trade policy, or a combination...more
Today, the U.S. Department of Homeland Security (“DHS”) issued a request for comments to assist the Forced Labor Enforcement Task Force (“FLETF”) with implementation of the Uyghur Forced Labor Prevention Act (“UFLPA”)...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
June’s G7 summit showed that eradicating forced labor in Xinjiang remains a top priority for leaders of the world’s most advanced economies. But what does this mean for international businesses with supply chains extending to...more
Review Your Supply Chain and Establish Compliance Plans Because Forced Labor Laws are Here to Stay - If passed, these bills will grant US Customs and Border Protection authority for a region-wide WRO enabling the agency...more
Just two weeks into CY 2021, US Customs and Border Protection (CBP) is expanding its enforcement efforts against forced labor in China. This follows months of increasing pressure from labor and human rights groups and...more
The Department of Homeland Security (DHS) blocked imports of cotton products from a major Chinese state-owned firm in the Xinjiang Uighur Autonomous Region (XUAR) on December 2, saying the company uses forced labor of ethnic...more
The US Government has taken action recently to step up enforcement against forced labor. As particular regions come under increased media scrutiny, the issue has renewed interest in Congress, which is considering several...more
On September 14, 2020, the Department of Homeland Security (DHS) through Customs and Border Protection (CBP) issued new withhold release orders (WRO) aimed at entities involved in the importation, downstream manufacturing,...more
Under the TFTEA, CBP has taken an increasingly enforcement-minded posture to prevent and penalize the importation of goods produced using forced labor into the United States. On August 13, 2020, CBP announced that it had...more