CBP Enforcement of Import Ban on Forced Labor Goods
Webinar: 1 CCS Credit
Goods made with forced labor (including prison or forced child labor) are banned from importation into the United States. Recently Congress passed two new laws paving the way for U.S. Customs and Border Protection to increase its enforcement of this ban. The first law eliminated a critical obstacle to CBP’s detention of goods suspected of being made with forced labor. The second created a rebuttable presumption that any North Korean laborers, employed in any country and anywhere in the supply chain, are presumed to be forced laborers.
CBP has already taken action to enforce these new standards. To avoid lengthy detentions of merchandise, importers should update their practices, procedures, and documents to address forced labor and the nationality of workers with respect to not only immediate vendors but also suppliers of materials further back in the supply chain. In addition, these issues may overlap with Office of Foreign Assets Control sanctions that generally prohibit U.S. persons from dealing with or providing payments to entities supplying North Korean workers to third-country projects, making it increasingly important to know your suppliers and their workforce partners.
Join us for a discussion of forced labor and related issues as they pertain to U.S. importers and exporters.
- changes to forced labor laws
- burden of proof for different types of forced labor inquiries
- CBP detention of goods and process for review
- current information on geographic areas of concern
- responding to CBP inquiries
- updating procedures and documentation
- ensuring compliance with OFAC’s North Korean sanctions
ELISE SHIBLES is a Member of Sandler, Travis & Rosenberg, P.A., resident in the San Francisco office. She advises and counsels clients on trade agreement and preference program requirements for a variety of different types of goods under U.S. and non-U.S. trade programs including NAFTA, QIZ, ASEAN-China and EU-Vietnam, among others. She also has extensive expertise in all aspects of textile and apparel trade and policy including classification, origin, marking, drafting and reviewing proposed legislation, and strategy for trade negotiations. She has represented the interests of numerous international companies in free trade negotiations, including rules of origin, customs procedures and market access.
MARILYN-JOY CERNY is a member of Sandler, Travis & Rosenberg, P.A. She specializes in customs law, international trade law, and export control law, with extensive experience in tariff classification of a wide variety of imported merchandise, and has represented clients on these matters before U.S. Customs and Border Protection and the U.S. Court of International Trade. She counsels clients on import regulations relating to country of origin marking, prior disclosures, penalties, free trade agreements, and the requirements of other government agencies with responsibilities over import transactions.