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 video episode of Fashion Counsel, Arent Fox Fashion & Retail Leader Anthony Lupo speaks with Consumer Products and Fashion & Retail Partner Angela Santos to discuss how companies can reduce import duties and prevent...more
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)
In the latest WorldSmart podcast, International Co-Chairs Hunter Carter and Malcolm McNeil sit down with Customs & Import Compliance Partner Angela Santos to discuss the global forced labor problem, how forced labor can...more
Senate passage of the Uyghur Forced Labor Prevention Act, issuance of the updated Xinjiang Supply Chain Business Advisory, and other recent government action may indicate that all products produced in whole or part in XUAR...more
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)
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