The U.S. government’s Forced Labor Enforcement Task Force (FLETF) has released its Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China—as mandated by the UFLPA.
This strategy, along with the UFLPA Operational Guidance for importers, provides the structure for the full implementation of the UFLPA, effective June 21, 2022. All businesses with products whose supply chains include Chinese materials should understand and implement this strategy and the operational guidance into their business operations.
Some key lists included in the strategy can be found below. Complete lists can be found on pages 22-25 of the strategy.
- Entities in Xinjiang that mine, produce, or manufacture wholly or in part any goods, wares, articles and merchandise with forced labor;
- Entities working with the government of Xinjiang to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of Xinjiang;
- Products mined, produced, or manufactured wholly or in part by such entities; and
- A list of facilities and entities, including the Xinjiang Production and Construction Corps, that source material from Xinjiang or from persons working with the government of Xinjiang or the Xinjiang Production and Construction Corps for purposes of the ‘‘poverty alleviation’’ program or the ‘‘pairing-assistance’’ program or any other government-labor scheme that uses forced labor
Key high-priority sectors for enforcement are:
- Apparel
- Cotton and cotton products
- Silica-Based Products (including polysilicon)
- Tomatoes and Downstream Products
If you have questions on the UFPLA strategy and guidance, please reach out to Mohawk Global Trade Advisors.