Updated: Importer Operational Guidance on China’s Uyghur Forced Labor Import Ban – Entity List Now Available

Workers in Chinese Factory w/ Barbed Wire (Photo Courtesy of the Coalition to End Forced Labour in the Uyghur Region)

Trade Update • June 20, 2022

U.S. Customs and Border Protection (CBP) has released operational guidance for importers to assist in preparing for the implementation the Uyghur Forced Labor Prevention Act (UFLPA), which goes into effect on June 21, 2022.

The UFLPA establishes a rebuttable import ban on any goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China, or produced by certain entities on the Forced Labor Enforcement Task Force (FLETF) Entity List, is prohibited by Section 307 of the Tariff Act of 1930 and that such goods, wares, articles, and merchandise are not entitled to entry to the United States.

Guidance Highlights (Updated)

Some highlights of this guidance are as follows:

  • Importers who receive a detention notice regarding their shipments may respond to CBP within 30 days from the date the merchandise is presented for examination to CBP, to request an exception to the UFLPA rebuttable presumption. The importer must be in compliance with specified conditions and, provide clear and convincing evidence, that their goods, wares, articles, or merchandise were not mined, produced, or manufactured wholly or in part by forced labor.
  • Importers must demonstrate due diligence, effective supply chain tracing, and supply chain management measures to ensure that they do not import any goods made, in whole or in part, by forced labor, especially from the Xinjiang Region.
  • Shipments imported prior to June 21, 2022 will be adjudicated through the WRO/Findings process. Shipments imported on or after June 21, 2022 that are subject to the UFLPA, which previously would have been subject to a XUAR WRO, will be processed under UFLPA procedures, and detained, excluded, or seized.
  • Update: A list of entities in Xinjiang that mine, produce, or manufacture wholly or in part any goods, wares, articles and merchandise with forced labor can be found here.

Questions? Need More Info?

Please frequently check CBP’s UFLPA webpage for the latest information on the UFLPA and send inquiries to the inbox.

Full guide can be found here.

Do you need help in reviewing your supply chain for to ensure your imports are compliant? Contact us, we’re here to help.


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