Background

Compliance with the new forced labor requirements in the CTPAT Trade Compliance program will yield three additional benefits announced this month by U.S. Customs and Border Protection.

According to CBP, 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 CBP announced the addition of six new CTPAT Trade Compliance requirements regarding the prevention of forced labor within the supply chain. CBP now states that, effective immediately, it will provide the following new benefits for compliance with these requirements to the greatest extent possible and practical.

- Partner companies that have shipments detained due to forced labor will have their admissibility packages prioritized for review by the appropriate Center of Excellence and Expertise. The importer must assert that it is an active member of the program and request prioritized review at the time supporting documentation is submitted. Upon this declaration, the Center should prioritize the processing of the package above other non-partner packages received within the Center team or division to the best of their ability.

- Partner companies that have shipments arrive at their facility that are later determined to be held due to ties to forced labor, where redelivery is normally requested, may hold their shipments intact at their facility rather than redelivering them to CBP until an admissibility determination is made or until a physical inspection is required.

- Partners that have a shipment detained by CBP due to a withhold release order will be allowed to move the goods to a bonded facility to be held intact until an admissibility determination is made by CBP.

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

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