Important Alert – Forced Labor
The Uyghur Forced Labor Prevention Act (UFLPA) was enacted on December 23, 2021 to strengthen the existing prohibition against the importation of goods mined, produced, or manufactured wholly or in part with forced labor in the People’s Republic of China (PRC), especially in the Xinjiang Autonomous Region, and imported into the United States.
Securing U.S. supply chains against forced labor will require cooperation across stakeholders, including industry, civil society, and federal agencies. All entities whose supply chains touch Xinjiang should undertake due diligence measures to ensure compliance with U.S. laws and trace their supply chains for potential exposure to forced labor.
Policy Change in Reporting the actual PRC Manufacturer
Effective March 18, 2023, the following MANDATORY information must be present on all commercial invoices used for customs clearance of commercial goods entering the United States.
- The full name, address, and postal code of the actual Chinese Manufacturer.
- CBP will no longer accept the name and information of other entities where purchases were made by U.S. Importers through selling agents, and middlemen companies. In these cases, the seller MUST list the actual manufacturer and their full name, address, and postal code on the commercial invoice(s).
- Import documentation that fails to contain the above information will subject the shipment(s) to detention.
The above information will be used to create specific Manufacturer’s Identification Numbers (MID) that will be matched against a forced labor manufacturers database to identify goods made wholly or in part with forced labor.
Any PRC manufacturer found to be in violation of forced labor laws will subject the shipment(s) to detention and exclusion authorities under 19 U.S.C. 1499, and seizure authorities under 19 U.S.C. 1595a(c).
Please contact your Chinese suppliers to inform them of these new mandatory requirements and the effective date of March 18, 2023.
If you require further information or clarification, please contact your Farrow Client Partnering Representative or your Farrow U.S. Representative.
View Farrow’s Global Consulting information.