Forced Labor Questionnaires: Another Helpful Hint

In February 2024, Customs and Border Protection (CBP) began taking a new approach to Uyghur Forced Labor Prevention Act (UFLPA) enforcement—questionnaires. Once again, the solar industry is among the first targets, vanguards among importers, hacking their way through new regulatory growth, hopefully exposing a clear way through for all who follow. Active enforcement mechanisms like questionnaires—and the Forced Labor Enforcement Task Force (FLETF) itself—are still evolving. But the prohibition on imports "manufactured wholly or in part [by] forced labor" is nearly 100 years old. Importers with serious compliance programs, and who have strategically contemplated their global networks in the UFLPA's light, already possess the basic tools required for compliance. CBP's demand regarding forced labor is the same now as it was in 1993, when Congress modified the Tariff Act of 1930 and clarified importers' duty of reasonable care: Know your value chains and be ready to prove