The U.S. Department of Homeland Security (DHS) Forced Labor Enforcement Task Force (FLETF) released an updated version of its Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor from the People’s Republic of China.
Strategic Background
DHS released the first publication of the UFLPA strategy in June 2022. The strategy outlines a multi-pronged approach to combating forced labor in global supply chains. The strategy includes risks of forced labor imports from China, high priority sectors for enforcement, guidance for importers, recommendations for accurately identifying affected goods, etc. DHS released the first update to the publication in August 2023.
the latest update
The update builds on the government’s two-year effort to enforce the Unified Non-Tariff Barriers Act. The latest strategy identifies new enforcement priority sectors – aluminum, polyvinyl chloride (PVC), and seafood. These sectors were identified because Uighurs and other ethnic minorities in the Xinjiang Uighur Autonomous Region (XUAR) face a higher risk of forced labor or state labor transfer.
Entities in these sectors will now be prioritized for review for enforcement actions such as listing on the UFLPA Entity List, sanctions, export restrictions, and visa restrictions.
Other products previously identified as high priority, such as apparel, cotton and cotton products, silicon-based products including polysilicon, and tomatoes, remain high priority industries.
The update also outlines how FLETF has significantly advanced its goals through initiatives such as robust enforcement by U.S. Customs and Border Protection (CBP), the expansion of the UFLPA Entity List, new high-priority areas for enforcement, and increased collaboration with stakeholders.
Revisit your due diligence
With the addition of these new enforcement focus areas, importers should place greater emphasis on due diligence efforts in supply chains that interact with these areas.
Diaz Trade Law has extensive experience in a wide range of import compliance matters, including forced labor compliance and enforcement mitigation. For assistance with a wide range of forced labor compliance matters, including developing or updating a forced labor compliance program, forced labor compliance training, or communicating with CBP regarding shipments detained by CBP, please contact us today at info@diaztradelaw.com.
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