Today, the Department of Homeland Security publicly released two key updates to its enforcement of the Uyghur Forced Labor Prevention Act (UFLPA), including additions to UFLPA entity list.and an updated strategy report to Congress on UFLPA
Additions to UFLPA entity list
Effective Aug. 2, 2023, the Forced Labor Enforcement Task Force is adding the following companies to the UFLPA entity list:
- Camel Group Co., Ltd.
- Chenguang Biotech Group Co., Ltd. and its subsidiary Chenguang Biotechnology Group Yanqi Co. Ltd.
Updated strategy report to Congress on UFLPA
As required annually, DHS published its “2023 Updates to the Strategy to Prevention the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China” to provide updates and additions to the UFLPA Strategy prepared by the Forced Labor Enforcement Task Force.
The UFLPA Strategy largely remains the same as expressed in its 2022 report, but now incorporates the updates to the list since it was initially published. The update to the enforcement plan indicates that WROs will not be issued on goods subject to the UFLPA because this law already puts in place the prohibition. CBP has the authority under 19 U.S.C. 1307 to detain, exclude, and/or seize and forfeit shipments within the scope of the UFLPA, making a WRO redundant. However, CBP makes clear it will continue to target shipments produced or exported by the entities listed under the UFLPA entity list, as well as finished goods exported by other manufacturers that contain inputs from these entities.
The formal list of high priority sectors has not been updated but the report does note other sectors of high risk, including red dates and other agricultural products, vinyl products and downstream products, aluminum and downstream products, steel and downstream products, lead-acid and lithium-ion batteries, copper and downstream products, electronics, and tires and other automobile components. CBP and ICE have requested additional funding for training and anticipated investigation efforts.
Sandler, Travis & Rosenberg has a robust program to assist companies on forced labor issues. ST&R also maintains a frequently updated web page offering a broad range of information on forced labor-related efforts in the U.S. and around the world. For more information, please contact ST&R at firstname.lastname@example.org.
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