A trade advisory committee is asking U.S. Customs and Border Protection to take several steps to provide importers and others with better information on its enforcement of forced labor prohibitions.

CBP’s Commercial Customs Operations Advisory Committee has recommended that CBP continue to pursue the development of a forced labor informed compliance publication but in the meantime publish a series of visual fact sheets to help U.S. importers to better understand the operational processes to comply with the Uyghur Forced Labor Prevention Act and withhold release orders. COAC wants these fact sheets to describe in a flowchart format CBP’s operational processes, including the following.

- detention to release, exclusion, or import entry rejection (e.g., steps importers should take to seek an exception to the UFLPA or request an applicability or admissibility review, and the process importers should follow for additional shipments that have identical supply chains to those that have been reviewed and determined to be admissible)

- process of requesting a CBP determination that a specific commodity import does not fall under the UFLPA or an active WRO (including where the importer should file the request and how to utilize the ruling received for future imports of the identical supply chain)

COAC has also recommended that CBP (1) develop a mechanism to receive additional questions and requests for new FAQs from the public, periodically review the posted FAQs, and publish updated FAQs as continuous training/awareness to the trade community, (2) revamp its forced labor and UFLPA web pages to clearly indicate when updates or changes are made to guidelines, operational processes, fact sheets, FAQs, etc., and actively push out such information (e.g., via the Cargo System Messaging Service) to customs brokers, importers, and the trade community, and (3) enhance its current quarterly forced labor enforcement statistics to include additional indicators about enforcement activity such as number of detentions, commodity types detained, country of origin of products detained, and number of shipments released.

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

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