The Forced Labor Enforcement Task Force (FLETF) has released their strategy required by the Uyghur Forced Labor Prevention Act (UFLPA). This 68-page document provides an overview of the UFLPA and forced labor issues in the Xinjiang region of China.
To combat forced labor concerns in Xinjiang, UFLPA carries a rebuttable presumption that all goods made wholly, or in part, in the Xinjiang Uyghur Autonomous Region (XUAR) have been produced with the benefit of forced labor. These goods are excluded from entry into the US, so importation of these products is denied unless the importer can provide clear and convincing evidence that the goods have no inputs produced by forced labor.
The document explains Customs’ strategy for enforcing UFLPA, including guidance on how they will determine if goods are in violation and future steps they may take to improve enforcement. The strategy includes an assessment of the risk of importing goods mined, produced, or manufactured with forced labor. The document also offers guidance to importers and a list of entities which have been linked to forced labor from the region. These entities are subject to a rebuttable presumption that they have been produced with forced labor. This entities list can be found on pages 22-25, and contains products that have been identified as high risk from suppliers.
Guidance to importers on the best strategy for avoiding the importation of goods with a forced labor component starts on page 48. This section contains recommendations for tracing your supply chain and creating an environment of compliance. Guidance in this section also addresses information an importer can provide to rebut the forced labor presumption.
The FLETF document is titled “Strategy to Prevent the Importation of Goods, Mined, Produced with Forced Labor in the People’s Republic of China” and can be found here.
Sam McClure, LCB
Director of Compliance & Customs Services
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Meet one of CVI’s Customs Brokerage & Compliance experts, Sam McClure:
Sam serves as Director, Compliance and Customs Services for CVI. He serves as CVI’s corporate compliance officer and is responsible for overseeing all aspects of our Customs related services, including growth.
Sam started his career in 1977 with Waters Shipping Company in Charlotte, NC. He began as a document runner, soon becoming a leader in operations and customer service for the branch. Sam, along with Linda Masten, founded Central Carolina Shipping Inc. in 1983 as an independent Customs Brokerage firm where he served as Vice President for 26 years. Sam and Linda grew Central Carolina into a successful and highly respected member of the Carolinas trade community. When Charlotte opened their local chapter of the IFFCBA Sam was part of the organizing group and he headed the Customs committee for several years. Sam obtained his Customs Brokers License in 1984 and remained with Central Carolina until the company was acquired by CVI in 2009.
At CVI, Sam has held several positions in both the operations and sales departments. As an expert in U.S. Customs regulations, Sam is often called upon on to provide guidance to importers on Customs compliance issues. He makes regular presentations on matters related to importation and broader regulatory compliance.
– Sam McClure, LCB, Director of Compliance & Customs Services, CVI
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