Forced Labor

  • Forced Labor / Sanctions Contract Provisions

    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 […]

  • UFLPA Due Dilligence

    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 […]

  • UFLPA

    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 […]

  • Forced labor tracing recommendations

    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 […]

  • Forced Labor

    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 […]

  • forced Labor

    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 […]

  • Forced Labor

    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 […]

  • 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 https://www.dhs.gov/sites/default/files/2022-06/22_0617_fletf_uflpa-strategy.pdf, but it’s already 9 months old. Answer 1: The last update that I am aware of is in August of 2022  https://www.federalregister.gov/documents/2022/08/04/2022-16754/notice-on-the-addition-of-entities-to-the-uyghur-forced-labor-prevention-act-entity-list 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 […]