Information made available by U.S. Customs and Border Protection highlights an evolving environment with respect to the agency’s enforcement of the Uyghur Forced Labor Prevention Act.
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 supplychainvisibility@strtrade.com.
The UFLPA establishes a rebuttable presumption that goods made wholly or in part in China’s Xinjiang Uyghur Autonomous Region are made with forced labor and are therefore excluded from entry into the U.S. All businesses with products whose supply chains include Chinese materials should understand both CBP’s importer guidance and the related enforcement strategy and ensure that they are being implemented into their business operations. Even companies not importing directly from China may have goods detained if the materials used to produce those goods in a second country are tied at any level to the XUAR or specific entities or commodities associated with forced labor in China.
In its updated dashboard CBP provides aggregate statistics on the number and value of shipments stopped for UFLPA enforcement as well as the industries and countries of origin most affected. Highlights of the most recent statistics include the following.
Stopped Shipments
- The number of stopped shipments increased 13.6 percent from 354 in April to 402 in May and the value of such shipments increased 14.8 percent from $156.8 million to $179.9 million.
- Of the 4,269 total shipments stopped since CBP began enforcing the UFLPA, 1,608 (37.7 percent) have been released, 679 (15.9 percent) have been denied, and 1,985 (46.4 percent) are still pending. For FY 2023 to date those figures are 35.8, 17.2, and 47.1 percent, respectively.
- Overall, electronics has been the industry sector accounting for the highest percentage of stopped shipments (46.8 percent), followed by apparel, footwear, and textiles (17.6 percent) and industrial and manufacturing materials (15.9 percent). For FY 2023 to date the leading sectors are electronics (34.8 percent), industrial and manufacturing materials (22.7 percent), and apparel, footwear, and textiles (20.5 percent).
- More than half the value of all stopped shipments to date (59.8 percent) has come from imports from Malaysia, followed by 27.9 percent from Vietnam and 11.5 percent from China. For FY 2023 to date those figures were 57.5 percent for Malaysia, 24.5 percent for Vietnam, and 17.8 percent for China.
- To date China has accounted for the largest percentage of stopped shipments (by number) at 36.7 percent, followed by Vietnam at 31.9 percent and Malaysia at 30.0 percent. For FY 2023 to date those figures are 41.3 percent for China, 32.4 percent for Vietnam, and 25.0 percent for Malaysia.
- All of the stopped shipments to date from Malaysia have been in the electronics sector. For Vietnam, 49.7 percent have been in electronics, 29.7 percent have been in industrial and manufacturing materials, and 20.4 percent have been in apparel, footwear, and textiles. For China, 27.7 percent have been in apparel, footwear, and textiles, 17.5 percent have been in industrial and manufacturing materials, and 16.5 percent have been in agriculture and prepared products.
Released Shipments
- Of all shipments released to date, the electronics sector accounts for 52.2 percent (by number), followed by consumer products and mass merchandising at 12.2 percent and apparel, footwear, and textiles at 12.1 percent. For FY 2023 to date the leading sectors are electronics at 46.3 percent, agriculture and prepared products at 15.7 percent, and apparel, footwear, and textiles at 13.9 percent.
- China has accounted for 43.2 percent of all shipments released (by number), followed by Malaysia at 34.8 percent and Vietnam at 19.7 percent. For FY 2023 to date those figures are 47.6 percent for China, 40.9 percent for Malaysia, and 10.2 percent for Vietnam.
- For Malaysia, all shipments released to date have been in electronics. For Vietnam, 80.1 percent (by number) have been in electronics, and for China the leading sectors are consumer products and mass merchandising at 28.2 percent and agriculture and prepared products at 26.7 percent.
Denied Shipments
- Of all shipments denied, apparel, footwear, and textiles account for 48.6 percent, followed by industrial and manufacturing materials at 24.7 percent and pharmaceuticals, health, and chemicals at 14.3 percent. For FY 2023 to date the leading sectors are apparel, footwear, and textiles at 46.9 percent, industrial and manufacturing materials at 33.8 percent, and pharmaceuticals, health, and chemicals at 8.3 percent.
- China has accounted for 66.1 percent of all shipments denied (by number), followed by Vietnam at 32.5 percent and Malaysia at 1.9 percent. For FY 2023 to date those figures are 60.3 percent for China, 39.5 percent for Vietnam, and 1.3 percent for Malaysia.
- Apparel, footwear, and textiles has accounted for 47.0 percent of all shipments denied (by number) for China and 56.1 percent for Vietnam. For FY 2023 those figures are 45.8 percent for China and 52.2 percent for Vietnam.
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