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
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
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
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
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
U.S. Customs and Border Protection (CBP) held The Forced Labor Technical Expo: Tools for Supply Chain Transparency from March 14-15, 2023, which involved members of the U.S. importing community, partner government agencies,...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
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
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
U.S. protection of labor rights in international trade has existed for almost 100 years under Section 307 of the Tariff Act of 1930 (19 U.S.C. § 1307). While it has been dormant for most of that span, enforcement has...more
It’s goes without saying, but I will say it anyway, the recent visit to Taiwan by U.S. House Speaker Nancy Pelosi certainly didn’t help the already strained relations much, but within her reasoning for defiance of Beijing,...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
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 U.S. photovoltaic (PV) industry, solar module suppliers, manufacturers, and renewable energy developers are facing new regulatory challenges with the implementation of new legislation which has a significant impact on...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