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CBP Has Released Updated Information on the Uyghur Forced Labor Prevention Act (UFLPA)

Updated: Jun 28, 2023

On December 23, 2021, the Uyghur Forced Labor Prevention Act (UFLPA) was signed into law and was later implemented on June 21, 2022. The act creates a presumption that products manufactured in the Xinjiang region of the People's Republic of China are prohibited due to forced labor and humanitarian concerns. The regulations stemming from this act have affected many importers doing business throughout China.

U.S. Customs and Border Patrol (CBP) has released a set of guidelines to inform importers of how they may be affected but most recently CBP has announced that alerts will be implemented into the Automated Commercial Environment (ACE). The updates include new postal code requirements for Cargo Release and Manufacturer Identification code applications. These new alerts will be implemented March 18, 2023.

The CBP general guidelines on UFLPA cover a very wide range of how importers may be effected while outlining the entire process from how goods may be detained to providing evidence that goods were not created by forced labor. CBP will not be releasing zip codes for the Xijiang region as they have indicated that it is part of an importer's due diligence to ensure that no entity in their supply chain touches the region or an entity on CBP's UFLPA Entity List.

CBP encourages importers to build very detailed supply chain tracing and due diligence systems for avoiding any contact with forced labor. CBP acknowledges that all products from the Xinjiang region may not be products of forced labor but UFLPA has created an extremely high standard for disproving that a particular product manufactured in this region did not come into contact with forced labor at any point of the supply chain.

Do you have questions about how UFLPA is affecting your business practices? Do you believe that you may need to submit evidence that goods originating in China were not manufactured by forced labor? Do you need help building your due diligence and supply chain tracing systems? Have questions? Give our office a call today at (917) 546-6997, we would be happy to speak with you.

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