UFLPA Enforcement Remains Work In Progress

U.S. Customs and Border Protection's ("CBP") implementation of the Uyghur Forced Labor Prevention Act ("UFLPA") remains a work in progress, as importers work to mitigate shipment detentions and respond to UFLPA reviews and enforcement actions. Emerging best practices may guide stakeholders as they navigate these uncertainties.

Develop a Due Diligence System

Due diligence systems allow companies to proactively evaluate forced labor risks within their supply chains through comprehensive information gathering and robust risk assessments, which can mitigate the legal and reputational consequences of forced labor.

To establish a due diligence system, a company should:

• Continuously collect information on Tier 1 – Tier 3 suppliers, to maintain comprehensive supply chain traceability;