US Customs and Border Protection (CBP) has released new Forced Labor Enforcement Operational Guidance for Importers, bringing together key information related to forced labor enforcement under three authorities: 19 U.S.C. § 1307, the Uyghur Forced Labor Prevention Act (UFLPA), and the Countering America’s Adversaries Through Sanctions Act (CAATSA).
The guidance consolidates previously scattered resources into a single reference document, providing importers with a clearer understanding of CBP’s enforcement approach and compliance expectations. It also includes industry-specific documentation recommendations and examples of CBP notices, offering insight into how enforcement actions may unfold in practice.
Understanding the Impact
Forced labor enforcement remains a significant focus for CBP, and importers are expected to maintain visibility throughout their supply chains—not just with direct suppliers, but across upstream sourcing networks as well.
Since the UFLPA took effect in 2022, CBP has reviewed or taken enforcement action on more than 69,000 shipments valued at nearly $3.9 billion. Industries including solar products, apparel, electronics, and industrial materials have seen heightened scrutiny.
The updated guidance provides greater transparency around CBP’s enforcement tools, including UFLPA reviews, Withhold Release Orders (WROs), Findings, and CAATSA-related actions. For importers, understanding these processes can help reduce uncertainty and improve preparedness if a shipment is detained, excluded, or selected for review.
What Importers Should Review
This guidance serves as a timely reminder to evaluate existing forced labor compliance programs and supply chain due diligence efforts.
Importers should consider reviewing:
- Supplier onboarding and vetting procedures
- Supply chain mapping and traceability practices
- Documentation retention policies
- Processes for responding to CBP requests and enforcement actions
In many cases, shipment delays are not caused by a lack of compliance efforts, but by an inability to quickly produce the documentation needed to demonstrate supply chain transparency. Having organized, accessible records can significantly improve response times and help mitigate disruption when enforcement actions occur.
Forced labor compliance continues to evolve, and CBP’s latest guidance reinforces the importance of proactive supply chain oversight. Organizations that understand their sourcing networks and maintain robust documentation will be better positioned to navigate enforcement actions and minimize supply chain disruptions. If you have questions about CBP’s updated forced labor enforcement guidance or would like to evaluate the strength of your import compliance program, reach out to Mohawk Global Trade Advisors.