Operational guidance for importers on the Uyghur Forced Labor Prevention Act (UFLPA) was released by the U.S. Customs and Border Protection (CBP) on June 13, 2022. Importers must refer to this guidance alongside the forthcoming specific importer guidance by the Department of Homeland Security and the UFLPA Entity List, both of which are due to be published in the Federal Register on June 21, 2022.

Importers can request an exception to the UFLPA presumption during a detention, after an exclusion, or during the seizure process. The types of supporting documentation CBP will require if an importer requests an exception include:

  • Due diligence system information
  • Supply chain tracing information
  • Evidence the goods were not mined, produced, or manufactured wholly or in part in Xinjiang
  • Evidence goods originating in China were not mined, produced, or manufactured wholly or in part by forced labor
  • Supply chain management measures

For a more detailed overview, please see our full article on reedsmith.com.