As CBP expands its enforcement efforts across multiple trade priorities—including the ongoing Section 301 investigations into supply chain practices and unfair trade and forced labor—importers should expect increased scrutiny of sourcing, supplier relationships, and documentation. Strong due diligence and supply chain transparency are becoming essential not only for forced labor compliance but for broader trade compliance as well.

With that said, it is not coincidental that U.S. Customs and Border Protection (CBP) has just published a new Forced Labor Enforcement Operational Guidance for Importers designed to help businesses better understand how the agency identifies and stops goods made with forced labor from entering the United States.

What Does This Mean for Importers?

The new guide brings together information from three different U.S. laws into one easy-to-reference resource. These laws allow CBP to detain, exclude, or seize imported goods if there is evidence that they were produced using forced labor. The guidance covers enforcement under:

  • 19 U.S.C. §1307, which prohibits the importation of goods made with forced labor.
  • The Uyghur Forced Labor Prevention Act (UFLPA), which presumes goods connected to China’s Xinjiang region are made with forced labor unless the importer can prove otherwise.
  • The Countering America’s Adversaries Through Sanctions Act (CAATSA), which restricts certain goods linked to North Korea and other sanctioned activities.
What’s New?

CBP has added several tools to make the enforcement process easier to understand:

  • A visual process map showing how CBP handles UFLPA reviews, Withhold Release Orders (WROs), Findings, and CAATSA actions.
  • Step-by-step explanations of what happens if your shipment is detained or excluded and what information CBP may request.
  • Practical appendices that include:
    • Examples of supply chain documentation for high-risk industries
    • Real-world due diligence examples under UFLPA
    • Sample detention notices, exclusion notices, Notices of Redelivery, and Certificates of Origin
What Should Importers Do?

CBP strongly encourages importers to take a proactive approach by:

  • Understanding where their products and raw materials originate
  • Vetting suppliers and manufacturers before goods are shipped
  • Maintaining documentation that demonstrates products are not made with forced labor
  • Being prepared to quickly respond if CBP requests additional information

The stronger your supply chain documentation, the better positioned you will be if CBP questions a shipment.

Bottom Line

Forced labor enforcement continues to be a major priority for CBP. The new guidance provides importers with a clearer roadmap of the agency’s expectations and enforcement procedures. Companies that perform thorough supplier due diligence and maintain comprehensive records will be better equipped to avoid costly shipment delays, exclusions, or enforcement actions.