Compliance Briefing — June 21, 2022
U.S. Customs and Border Protection began enforcing the Uyghur Forced Labor Prevention Act on 21 June 2022, presuming goods from Xinjiang involve forced labor unless importers rebut the claim.
Executive briefing: The Uyghur Forced Labor Prevention Act (UFLPA) entered into force on 21 June 2022. CBP now applies a rebuttable presumption that goods mined, produced, or manufactured wholly or in part in China’s Xinjiang region involve forced labor, blocking their entry unless importers provide clear and convincing evidence to the contrary.
Key compliance checkpoints
- Supply chain tracing. Map upstream suppliers and sub-suppliers to raw material level, documenting geographic sourcing outside Xinjiang.
- Due diligence files. Collect evidence packages—including supplier affidavits, transaction records, and third-party audits—to rebut presumptions.
- Compliance program elements. Implement forced labor policies, training, and escalation procedures aligned with UFLPA strategy guidance.
Operational priorities
- Screening. Cross-check suppliers against the UFLPA Entity List and other forced labor watchlists.
- Import documentation. Prepare electronic entry filings with traceability documentation ready for CBP detention reviews.
- Remediation. Establish corrective action plans, including supplier disengagement, when forced labor indicators arise.
Enablement moves
- Adopt digital traceability platforms capable of recording provenance, processing steps, and proof of origin.
- Engage accredited auditors to perform social compliance assessments and provide affidavits supporting rebuttal packages.
- Coordinate legal, trade compliance, and procurement teams to respond swiftly to CBP detention notices.
Sources
Zeph Tech advances UFLPA compliance with supply-chain tracing, documentary evidence management, and detention response playbooks.