Isotopic Testing: A Vital Component of U.S. Importer Due Diligence

Trade Update • Nov. 21, 2024

he U.S. Customs and Border Protection (CBP) has published a comprehensive guide on isotopic testing to assist importers in improving supply chain oversight. This method supports efforts to verify the origin of raw materials, fulfill compliance obligations, and demonstrate due diligence, particularly under the Uyghur Forced Labor Prevention Act (UFLPA).

What is Isotopic Testing?

Isotopic testing is a scientific process that analyzes the atomic composition of natural materials influenced by environmental factors in specific geographic regions. The guide emphasizes the use of light stable isotopic analysis to verify the origins of materials such as cotton. CBP employs this testing to evaluate risks within supply chains, focusing on shipments associated with forced labor, including those linked to China’s Xinjiang Uyghur Autonomous Region (XUAR). Under the UFLPA, goods from this region are presumed to involve forced labor and are prohibited from entering the United States.

CBP’s Expanded Testing Capabilities

CBP is increasing its isotopic testing capacity at laboratories in Savannah, Los Angeles, and New York. These enhancements aim to enable quicker and more frequent testing. However, the agency acknowledges its limited capacity and emphasizes the need for importers to adopt private-sector isotopic testing as part of their due diligence programs.

Selecting a Testing Provider

CBP’s guidance advises importers to choose testing providers that adhere to best practices, such as those outlined by the Forensic Isotope Ratio Mass Spectrometry (FIRMS) Network. Recommended criteria include ISO/IEC 17025 accreditation, a robust geographic reference library, and proven proficiency in isotopic analysis. Laboratories should also ensure traceability through a detailed chain of custody for tested samples.

The Role of Isotopic Testing in Compliance

While isotopic testing is a powerful tool, CBP highlights that it should not be relied upon as the sole method of compliance. Importers are encouraged to integrate it into broader risk management strategies. The guide outlines essential elements of test reports, such as detailed product descriptions, sample origins, and statistical confidence levels, to enhance the accuracy and reliability of origin verification.

By leveraging isotopic testing, importers can better trace the origins of raw materials and strengthen their supply chain compliance programs. CBP’s guidance underscores the importance of science and collaboration in combating forced labor and ensuring transparency in global trade.

Access CBP’s Isotopic Testing Guide

Questions about importer due diligence compliance? Email us at: gts@ghy.com, or call: +1 (800) 667-0771