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ARTICLE · 14 JULY 2022

New Forced Labor Presumption Creates New Challenges For Global Supply Chains

Jones Day
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The Uyghur Forced Labor Prevention Act's rebuttable presumption went into effect on June 21, 2022, presumptively excluding goods produced in China's Xinjiang region from entering the United States.

GlobalInternational Law
Bethany Biesenthal
Bethany Biesenthal
Andrew E. Lelling
Andrew E. Lelling
David Morrell
David Morrell
Schuyler J. Schouten
Schuyler J. Schouten
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In Short

The Situation: The Uyghur Forced Labor Prevention Act's rebuttable presumption went into effect on June 21, 2022, presumptively excluding goods produced in China's Xinjiang region from entering the United States.

The Result: Companies should review recently published guidance and be prepared to respond to potential inquiries by U.S. Customs and Border Protection.

Looking Ahead: Combatting forced labor has been a central focus of the federal government in recent years, and signs indicate that further legislation and enforcement actions are likely. Companies should proactively review all steps in their supply chains accordingly.

The Uyghur Forced Labor Prevention Act ("UFLPA" or the "Act") imposes new obligations on companies producing or sourcing goods from the Xinjiang Uyghur Autonomous Region of the People's Republic of China ("Xinjiang"). The key provision of the Act establishes a rebuttable presumption that all items produced wholly or in part

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