Five Questions, Five Answers: Is there Forced Labor in Your Supply Chain? Prevent Costly Import Detentions at the Border
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
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
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
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
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
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
The Biden Administration’s interest in reducing the occurrence of forced labor or indentured child labor in the global supply chain, and the parallel goals of corporate social responsibility, are driving increased attention...more
Private Carriage Stand-Up: Where to Begin When In-Sourcing Transportation - An emerging trend in this era of supply chain disruption is the interest of large enterprise shippers, often in the consumer retail space, to...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
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
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
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 Situation: Companies are facing increased pressure by U.S. Customs and Border Protection ("CBP") and other federal agencies to demonstrate that goods imported into the United States were produced without the use of forced...more