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
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
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
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 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
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
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
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
On Thursday, December 23, 2021, President Biden signed the Uyghur Forced Labor Prevention Act (the “Act”) into law. The Act aims to “ensure that goods made with forced labor in the Xinjiang Uyghur Autonomous Region of the...more
U.S. Customs and Border Protection (CBP) on June 24, 2021, issued a Withhold Release Order (WRO) on silica-based products produced by Hoshine Silicon Industry Co. Ltd. (Hoshine) and its subsidiaries. Hoshine makes...more
U.S. Customs and Border Protection (CBP) is aggressively enforcing the Withhold Release Order (WRO) on products from the Xinjiang Uyghur Autonomous Region (XUAR) of China. CBP issued the region-wide WRO on Jan. 13, based on...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
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
On December 2, 2020, U.S. Customs and Border Protection issued an order preventing certain imported cotton products from China from being released to the importer. The products were made by Xinjian Production and Construction...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
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