U.S. Customs and Border Protection has released updated Forced Labor Enforcement Operational Guidance for Importers, consolidating its enforcement framework for goods potentially produced with forced labor in a single document.
The guidance brings together CBP’s three main authorities to address forced labor risk in imports:
- 19 U.S.C. § 1307
- the Uyghur Forced Labor Prevention Act, and
- Countering America’s Adversaries Through Sanctions Act (CAATSA)
The updated guidance is intended to improve transparency and provide importers with clearer insight into CBP’s enforcement processes and expectations. By consolidating existing guidance into one resource, CBP aims to help importers better understand how forced labor risks are identified, investigated, and addressed throughout the importation process.
In addition, the guidance includes several new appendices containing examples of due diligence measures, recommended supply chain documentation, and sample CBP notices, including detention, exclusion, seizure, and redelivery notices. These materials provide practical examples that may assist companies in evaluating and strengthening their compliance programs, supply chain tracing efforts, and documentation practices.
Given CBP’s continued focus on forced labor enforcement, importers should consider reviewing their existing compliance procedures and supply chain due diligence programs to ensure they remain aligned with current expectations.
Please reach out if you would like to discuss this update or review best practices for compliance in light of this update.
