U.S. Customs and Border Protection (CBP) has announced that importers, or their authorized filers, can submit a request to the Port Director to update the entry type to warehouse entry from a formal entry—where their cargo is being detained for forced labor concerns—requesting their cargo be transferred to a customs bonded warehouse for storage, pending resolution. However, CBP also made clear that the cargo cannot be moved to a Foreign Trade Zone (FTZ) for storage. 

The Commercial Customs Operations Advisory Committee’s (COAC) Forced Labor Working Group asked CBP to provide more guidance on FTZ and goods detained for forced labor concerns. One of the working group’s recommendations was that CBP make a change to the data elements on the CBP form 214 to enforce Uyghur Forced Labor Protection Act (UFLPA) in the FTZ environment.

Port Directors have the authority to approve or deny any request and will do so based on the circumstances at their port. If the request is approved, the importer or their authorized filers can update the entry type from a formal entry (e.g. Entry Type 01) to a bonded warehouse entry (Entry Type 21). If denied, then no changes should be made to the original entry.

Importers should contact the detaining port of entry with questions related to the request to move cargo. Other questions on this guidance should be directed to the Forced Labor Division at forcedlabor@cbp.dhs.gov.

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