CBP Releases Updated Forced Labor Guidance for Importers

U.S. Customs and Border Protection (CBP) has released updated Forced Labor Enforcement Operational Guidance for Importers, expanding prior guidance to cover all forced labor enforcement authorities—not just the Uyghur Forced Labor Prevention Act (UFLPA).

This update is intended to help importers better understand CBP’s expectations and enforcement processes related to goods that may be produced with forced labor.
CBP enforces prohibitions on forced labor imports under several authorities, including:

• 19 U.S.C. § 1307
• Uyghur Forced Labor Prevention Act (UFLPA)
• Countering America’s Adversaries Through Sanctions Act (CAATSA)

The updated guidance consolidates these authorities into a single resource and provides greater clarity around CBP’s enforcement approach.

Key highlights include:

•  A consolidated view of enforcement across UFLPA, WROs/Findings, and CAATSA
• Step-by-step insight into how CBP handles detentions, exclusions, and admissibility decisions
• Additional resources, including recommended supply chain documentation, due diligence examples, and sample CBP notices

While the underlying requirements have not changed, CBP is placing increased emphasis on supply chain awareness and documentation. Importers should be prepared to clearly demonstrate that their goods are not produced with forced labor, particularly if shipments are subject to review.

We encourage importers to review the guidance and ensure appropriate due diligence and supporting records are in place prior to import.

CBP’s full guidance is available here.

Casey Murphy
Asst. Director, Compliance & Customs Services
CV International, Inc.