At a recent meeting the Commercial Customs Operations Advisory Committee’s Forced Labor Working Group provided an update on U.S. Customs and Border Protection’s efforts to enforce the prohibition on imports made with forced labor, including the Uyghur Forced Labor Prevention Act.
(CBP informed COAC members earlier this year that it is bringing all existing subcommittees and workgroups to a close and plans to restructure them to focus on issues like national security, protecting domestic industry, and trade enforcement.)
New Submission Portal
In June 2025 CBP announced a new portal that allows trade community users to submit allegations when they have evidence that companies are using forced labor to undercut U.S. businesses and manufacturing. COAC now states that in fiscal year 2026 CBP plans to release a separate portal designed to increase efficiency and transparency, both internally and externally, regarding forced labor detentions and reviews.
According to a COAC document, the trade community will be required to use this portal to submit forced labor-related review submissions, including modification petitions, withhold release order admissibility reviews, and UFLPA applicability and exception reviews. Quick reference guides with step-by-step instructions on how to submit the various review requests are expected to accompany this portal.
Importer Guidance
In June 2023 CBP published its initial “Operational Guidance for Importers” document regarding imports of goods made with forced labor. The working group noted that since that time CBP’s policies regarding the types of evidence that must be produced, and the trade’s understanding of how to present such evidence to CBP, have evolved and matured. In addition, new technologies have been developed to help importers trace their supply chains and demonstrate that their goods are free of forced labor.
Taking into account COAC’s recommendations for improving this document, CBP has submitted a draft update to the working group for review and anticipates issuing a final version by the end of FY 2025. Topics to be covered in this update include operational guidance regarding detention and CBP enforcement, the type and nature of documentation required for supply chain tracing, and resources for supply chain tracing.
Other
Asserting that collaboration between private industry and CBP on commercial trade policy will continue, the working group expressed hope that such future work will include CBP (1) providing concrete and reliable data that businesses can rely on in establishing due diligence programs and (2) continuing to consider creating a trusted trader program centered on vetting protocols that businesses use to screen their supply chains.
Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address forced labor concerns around the world, including supply chain reviews, due diligence strategies, and proactive remediation. ST&R also maintains a 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.
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