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ARTICLE · 10 JULY 2026

New Compliance Tools: CBP Issues Comprehensive Forced Labor Guidance

Holland & Knight
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U.S. Customs and Border Protection has released comprehensive operational guidance consolidating forced labor enforcement across multiple statutory authorities. The guidance clarifies detention procedures, review pathways, and evidentiary requirements while introducing new process maps to help importers navigate UFLPA, CAATSA, and traditional forced labor enforcement mechanisms.

United StatesInternational Law
Andrew McAllister
Andrew McAllister
Ashley Akers
Ashley Akers
Molly B. O'Casey
Molly B. O'Casey
Manny Levitt
Manny Levitt
Noah Curtin
Noah Curtin
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Highlights

  • U.S. Customs and Border Protection (CBP) recently published its Forced Labor Enforcement Operational Guidance for Importers (2026 Guidance), replacing its June 2022 Uyghur Forced Labor Prevention Act (UFLPA)-only guidance with a consolidated forced-labor enforcement reference.
  • The 2026 Guidance addresses the UFLPA, Section 321A of the Countering America's Adversaries Through Sanctions Act and 19 U.S.C. § 1307 enforcement through Withhold Release Orders and Findings.
  • CBP has clarified the routes for detention, exclusion, seizure, review and protest, but importers must be ready to prove admissibility quickly and with complete supply-chain evidence.

U.S. Customs and Border Protection (CBP), on June 9, 2026, published its Forced Labor Enforcement Operational Guidance for Importers (2026 Guidance), replacing its June 2022 Uyghur Forced Labor Prevention Act (UFLPA)-only guidance with a consolidated forced-labor enforcement reference.

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