In 2020, leaders of Canada, the United States, and Mexico signed the United States Mexico Canada Agreement (USMCA) which, for the first time in a US free trade agreement, includes a ban on imports of products produced using...more
CBP Tech Expo Confirms No Existing “Silver Bullet” Technology and CBP Dashboard Reveals Every Industry Is Subject To Forced Labor Detentions -
On March 14-15, 2023, at US Customs and Border Protection’s (CBP) Forced Labor...more
US Customs and Border Protection (CBP) recently implemented mandatory forced labor requirements to participate in the Customs Trade Partnership Against Terrorism (CTPAT) and CTPAT Trade Compliance programs.
The previously...more
11/23/2022
/ Code of Conduct ,
Compliance ,
Customs and Border Protection ,
Due Diligence ,
Forced Labor ,
NAM ,
Penalties ,
Supply Chain ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
On October 18, 2022, US Customs and Border Protection (CBP) published the long anticipated final rule for the modernization of Customs broker regulations under 19 CFR part 111.
The rule will go into effect on December 19,...more
The US and EU have ramped up their enforcement initiatives to eliminate forced labor in supply chains. Importers, particularly in the fashion, electronics, solar, and automotive industries, should review the updated DOL List...more
10/13/2022
/ Automotive Industry ,
Child Labor ,
Customs and Border Protection ,
Department of Labor (DOL) ,
Electronics ,
Enforcement ,
EU ,
Fashion Industry ,
Forced Labor ,
Labor Regulations ,
Solar Panels ,
Uyghur Forced Labor Prevention Act (UFLPA)
US Customs and Border Protection (CBP) UFLPA Operational Guidance for Importers (CBP Guidance) was published on June 13, 2022 to assist importers in preparing for the UFLPA rebuttable presumption that goes into effect on June...more
US Customs and Border Protection (CBP) has issued some guidance relating to its enforcement of the Uyghur Forced Labor Prevention Act (UFLPA) prior to June 21, 2022, the effective date of the rebuttable presumption.
US...more
On January 24, 2022, The US Department of Homeland Security (DHS), on behalf of the Forced Labor Task Force (Task Force), published a Federal Register Notice to request public comments regarding the implementation of the...more
US importers should participate in the Task Force's comment and hearing process to flag due diligence challenges and formulate the strategy to enforce the import prohibitions.
What to Know -
Effective June 21, 2022, 180...more
1/6/2022
/ China ,
Customs and Border Protection ,
Detention ,
Enforcement ,
Export Administration Regulations (EAR) ,
Forced Labor ,
Human Rights ,
Importers ,
Office of Foreign Assets Control (OFAC) ,
Tariff Act of 1930 ,
Uyghur Forced Labor Prevention Act (UFLPA)
In this installment of the Five Questions, Five Answers podcast, Director of North American Manufacturing Birgit Matthiesen, Partner Angela Santos, and Associate Christine Hintze discuss the impact of US Customs' crackdown on...more
Brands Must Ensure Forced Labor is Not Used and Environmental Claims are Accurate -
In response to consumer demand, the fashion industry has embraced Environmental, Social, Governance (ESG) sourcing, including...more
11/5/2021
/ Child Labor ,
Corporate Social Responsibility ,
Customs and Border Protection ,
Environmental Social & Governance (ESG) ,
Fashion Branding ,
Fashion Industry ,
Federal Trade Commission (FTC) ,
Forced Labor ,
Goods or Services ,
Green Guides ,
Human Rights ,
Human Trafficking ,
Imports ,
Product Labels ,
Risk Mitigation ,
Slavery ,
Supply Chain ,
Sustainable Business Practices
CBP Adds Second Forced Labor Investigations Branch and DHS Publishes Timeline for Actions -
Importers should be prepared for increased forced labor actions (including new Withhold Release Orders and product import bans)...more
10/1/2021
/ Africa ,
Child Labor ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Due Diligence ,
Forced Labor ,
Importers ,
Latin America ,
Middle East ,
Supply Chain ,
Withhold Release Orders (WROs)
Forced Labor Enforcement Continues to Escalate as Commerce Restricts Exports to 5 Additional PRC Companies -
Withhold release order was issued that will prohibit imports of products produced in whole or part from silica...more
6/28/2021
/ Biden Administration ,
Child Labor ,
China ,
Customs and Border Protection ,
Department of Labor (DOL) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Exports ,
Forced Labor ,
Human Rights ,
Imports ,
Solar Energy ,
Supply Chain ,
US State Departments ,
Withhold Release Orders (WROs)
First sale appraisement currently remains a legally viable duty savings avenue, including for transactions with vendors in NMEs.
On March 1, 2021, Judge Thomas J. Aquilino, Jr. of the US Court of International Trade (CIT)...more
CBP is leveraging the EAPA to target various industries based on a suspicion of evading AD/CVD duties by aggressively scrutinizing imports potentially covered by an AD/CVD order.
On March 4, 2021, US Customs and Border...more
Review Your Supply Chain and Establish Compliance Plans Because Forced Labor Laws are Here to Stay -
If passed, these bills will grant US Customs and Border Protection authority for a region-wide WRO enabling the agency...more
3/5/2021
/ China ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Forced Labor ,
Global Magnitsky Act ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Proposed Legislation ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Tariff Act of 1930 ,
Withhold Release Orders (WROs)
Companies in the fashion, luxury, and agricultural spaces should take action in response to the forced labor supply chain due diligence requirements Customs recently announced in connection with withhold release orders (WRO)...more
Just two weeks into CY 2021, US Customs and Border Protection (CBP) is expanding its enforcement efforts against forced labor in China.
This follows months of increasing pressure from labor and human rights groups and...more