Question: UFLPA compliance is incredibly difficult. We have some products with literally thousands of sub-SKUs and chasing everything down to the ore level is onerous at best and impossible at worst. (Think Tier 6 suppliers. Getting data from, say, a sub-sub-sub-sub-sub-supplier? Good luck.) But if we don’t, our products get excluded. So is complete compliance our […]
Question: How does CBP determine which imports will get stopped for a UFLPA suspicion? All goods of COO China? Based on the MID? Answer 1: While COO China and MIDs linked to flagged regions or companies are major factors, CBP employs a combination of data, intelligence, and risk analysis to determine which shipments are stopped […]
Question: When goods are stopped on UFLPA suspicion, what does a rebuttal submission look like? What information do we need to provide in order to substantiate our claim that we’ve done our due diligence and forced labor does not apply to our import? We know it’s more than a mere supplier declaration, but HOW MUCH […]
Question: We are a US company registered as a NRI in Canada and trying to determine if we need to report. Based on the reporting requirements it states the following below. Does it apply only to assets in Canada and revenue for sales into Canada or do we have to look into our global revenue […]
Question: We received containers of material that were released by CBP more than two weeks ago. Much of this material was on backorder and was immediately shipped out of our inventory. This morning, we were notified by CBP that we were being ordered to return the material due to suspected UFLPA content. We have little […]
Question: I recall that some entity published model forced labor & sanctions language for use in contracts, but could not recall who published them. Do any of you have standard boilerplate language to include in contracts for either (e.g. [party] warrants and agrees that it shall not employ the services of any entity on any […]
Question: We are a long time CTPAT participant and our vendor is also a long time CTPAT participant. Our business partner screening process requests vendors to confirm compliance with UFLPA, and we have written confirmation from all of our vendors that they do not use forced labor in their supply chain. However, this particular vendor […]
Question: Is anyone willing to share their procedures for UFLPA compliance? How you respond to requests from customers, do you solicit your Chinese suppliers? Asked by: David Thomas – dave.thomas@harman.com Answer 1: We’re still feeling our way through this. But one thing we’ve done is ask our suppliers to document their supply chains all the […]
Question: I am looking for recommendations from the group for a Forced/Child labor and hopefully, other risks management and supply chain mapping solution. I really want to receive recommendations from members that are using the specific solutions. Asked by: – compliancequestions1@gmail.com Answer 1: I would suggest looking into the BITE platform. You can look at […]
Question: Does anyone know of a import license or exception for bringing in goods that are produced by forced labor for R&D purposes? Answer 1: No such thing exists and I would not want to knowingly import something into the U.S. that I know was produced in whole or in part with forced labor. Answered […]
Question: Hello members, Concerning the forced labor in China, how to avoid the risk that our goods are detained by U.S. Customs, in case we check the postal code of the shipper / manufacturer and everything, but the company has other sites that are not known to us, would we be responsible? How to do […]
Question: Deep, thorough supply chain knowledge is required to adequately attest for Forced Labor accuracy. How are companies managing this internally since external providers can only review the last-touch supply leading into import. If attestations are not sufficient from suppliers, how can companies manage? Answer 1: You are right, that suppliers are used to only […]
