Effective March 18 Customs will deploy the Regional Alert Enhancement to the Uyghur Forced Labor Prevention Act (UFLPA). The enhancement will allow Customs to provide notification to importers or their brokers that their goods may have been produced in the Xinjiang Uyghur Autonomous Region (XUAR) and therefore included in the scope of UFLPA. Goods from the XUAR are under a rebuttable presumption of forced labor which may lead to the cargo being excluded from importation into the US.
Customs will make their determination at least partially based the postal code provided in the entry transmission and a valid postal code will be required for any shipper or manufacturer in China. Failure to provide a valid postal code will result in a rejection from Customs and hold up the release of the cargo. Care should be taken to ensure the postal code provided is accurate, allowing for a correct UFLPA determination to be made. Detentions based on a suspected UFLPA violation can be very expensive so any goods not from the XUAR region should reflect a postal code that allows for a correct determination. Conversely goods from this the XUAR should carry the correct code so that Customs can enforce the act and check for any allowed exclusions. Unless unavailable the postal code provided should be that of the street address and not the city level code. Manufacturer information is provided to Customs via a MID code which is constructed from the name and address of the company. Any of these codes currently on file with Customs which do not include the postal code will need to be updated.
Customs is not providing a list of postal codes for China but you can see more information on the Regional Alert on the Customs website here. Customs also provides operational guidance, including the process for requesting an exemption to the UFLPA rebuttable presumption, at https://www.cbp.gov/document/guidance/uflpa-operational-guidance-importers.
Best Regards,
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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