Forced Labor

  • Language used to notify suppliers of the UFLPA

    Question: Can the ICPA membership advise what language is used to notify suppliers of the UFLPA given China blocking laws? Are importers explicitly referencing UFLPA in their requests for Affidavits and are suppliers responding? Answer 1: We have been using a version that does not specifically mention UFLPA. Our clause reads: Seller represents and warrants […]

  • UFLPA Entity List

    Question: Where can one find the most up-to-date UFLPA Entity List?  The most recent and complete I could find is at, but it’s already 9 months old. Answer 1: The last update that I am aware of is in August of 2022 They will update it when they are ready.  The website list […]

  • Withhold Release under UFLPA

    Question: When CBP detains a shipment with a WRO under the UFLPA:  If multiple containers and the suspect items are all in one container, may the remaining containers be released?   If we decide to export, may we export the one container?  If a container has both suspect items and non-suspect items, may we separate them […]

  • UFLPA compliance

    Question: At the CBP Forced Labor Expo, several industry presenters’ methods involved tracing chemical elements in products to look for fingerprints of where materials were grown or mined.  I’m interested in other professionals’ experience with this approach. Please do not mention any company names as the ICPA wishes to remain as neutral and not show […]

  • Forced Labor How to segregate a CN FL part from a full container shipment

    Question: Hi: Haven’t seen how an importer will be required to handle a full container shipment of parts IF CBP identifies a CN origin part as being suspected of having been produced with forced labor? We will be permitted to move the container to a bonded facility to unload, segregate out the part or parts […]

  • Vendor Due Diligence – ESG

    Question: Does anyone have a vendor form they can share to send out to new vendors to gather information about their supply chain (where are their manufacturing sites, etc.)? I’m trying to help our Procurement team with best practices when selecting vendors that will cover all required checks they should be doing prior to setting […]

  • UFLPA Detentions of Aluminum Products

    Question: Hi all, Wondering if anyone has heard anything beyond the minimal information that AP Moller-Maersk provided on Tuesday regarding CBP issuing detention notices for “aluminum products” under the UFLPA ( Specifically: Whether certain shippers/suppliers or importers were targeted? Whether goods not directly of Chinese origin (e.g., transshipped through a 3rd country or goods manufactured […]

  • UFLPA Forced Labor Detention Documentation Response

    Question: As the UFLPA/forced labor issue is a new regulation and many importers importing from China have many questions and concerns should there shipment(s) be detained by CBP, I’ve be tasked to create a “mock detention response documentation packet” to provide to potential suppliers that clearly explains our requirements of them. We plan to incorporate […]


    Question: Does anyone know the potential fines and penalties that can be assessed against an importer found to be out of compliance with the UFLPA requirements?  I am putting together a training presentation about UFLPA and want to show a slide with potential ramifications and impacts of non-compliance. Has anyone heard of any real life […]

  • Sime Darby, WRO Palm Oil

    Question: We have up to 40 containers in storage due to goods produced with Sime Darby palm oil.  (How?  Good question, considering the WRO went into effect in 2020!!)  We were advised there was a decision to store goods in the US pending entry because there was “hope” Sime Darby would fall off the WRO […]

  • XUAR Forced Labor

    QUESTION: Now that it has been a month since the presumption that goods from XUAR are made with forced labor has been in place, has the membership been seeing WROs imposed on their goods? If you have, what type of goods have been stopped? And where was the immediate supplier from? Particularly interested if anyone […]