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Chinese Import Ban: What the Uyghur Forced Labor Prevention Act Means For You - Webinar

Thursday, February 3, 2022 2:00 PM EST

Forced labor enforcement expands to all types of goods with new US law

Recently Congress passed the Uyghur Forced Labor Prevention Act (UFLPA), paving the way for U.S. Customs and Border Protection (“CBP”) to increase its enforcement efforts to combat forced labor. Effective June 21, 2022, the law creates a rebuttable presumption that any work performed in China’s Xinjiang Uyghur Autonomous Region (XUAR) is presumed to be forced.  As a result, all types of goods from any country that may have raw materials, components, subcomponents made, or some type of processing in the XUAR will be banned unless the importer can rebut the presumption of forced labor.  The law also includes new sanctions provisions.

CBP’s enforcement tools on these issues has included refusing entry of shipments until the Importer can prove with a high degree of certainty that there was no connection to the region.  CBP has also audited numerous importers for its procedures and processes to combat forced labor and tracing of sample shipments.  Importers should prepare for additional enforcement by reviewing and updating practices, procedures and recordkeeping to address forced labor, mapping and educating supply chain entities, and screening direct and indirect suppliers against sanction lists.  These activities may be further complicated by China’s relatively new anti-sanctions law.

 Key topics:

  • Summary of new Uyghur Forced Labor Prevention Act;
  • Preparing for forced labor enforcement;
  • China anti-sanctions law;
  • Burden of proof to rebut the presumption of forced labor;
  • Current Customs enforcement tools for forced labor;
  • U.S. sanctions against entities involved in Uyghur forced labor; and
  • Other potential geographic areas of concern.

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