U.S. Customs and Border Protection recently announced another benefit for companies complying with the forced labor criteria added to CTPAT Trade Compliance last year.

CTPAT Trade Compliance is a component of the larger CTPAT Security program that requires participants to meet all regulatory requirements of CBP and other government entities, maintain evidence of no financial debt to the U.S. government, and meet annual requirements. This program is voluntary and includes U.S.- and Canada-based importers that have at least two years of import history, are current Tier II or Tier III security partners in good standing, and have made a commitment of resources to assume responsibility for monitoring their own compliance.

On Aug. 1, 2022, U.S. Customs and Border Protection announced new minimum security criteria under CTPAT Trade Compliance related to forced labor. New program applicants must meet these requirements to be accepted, and existing program members must implement them by Aug. 1, 2023. CBP subsequently announced three new benefits for compliance with these criteria: front of the line admissibility review, redelivery hold, and detained withhold release order shipments moved to a bonded facility.

CBP has now implemented a further benefit for compliance with the forced labor criteria: to the best of its ability, CBP will provide advance notice of a possible hold, detention, exclusion, and/or seizure of merchandise after the entry is filed for cargo arriving in the U.S. and subject to the Uyghur Forced Labor Prevention Act. Notifications will include the entry number and associated lines that may be subject to a detention, exclusion, and/or seizure.

CBP states that it will be unable to provide further information regarding the entry and the data it contains beyond what is provided in the notification but that such information may be obtained from the importer’s customs broker. CBP adds that the notification does not denote any final decision but may be used by the importer to prepare for a possible shipment hold, detention, exclusion, and/or seizure.

For more information on CTPAT issues, please contact attorney Lenny Feldman via email or at (305) 894-1011.

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