The latest on Russia sanctions from the International Trade and Supply Chain Team
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On June 13th, Customs and Border Protection (“CBP”) released its Operational Guidance For Importers to prepare companies for the Uyghur Forced Labor Prevention Act (“UFLPA”). UFLPA enforcement is set to take effect June 21st and will apply a rebuttable presumption standard to imports tied in whole or in part to the Xinjiang Uyghur Autonomous Region or entities identified by the U.S. government on the soon to be published UFLPA Entity List.

Continue Reading CBP Releases Uyghur Forced Labor Prevention Act (UFLPA) Guidance for Importers

Today, the U.S. Department of Homeland Security (“DHS”) issued a request for comments to assist the Forced Labor Enforcement Task Force (“FLETF”) with implementation of the Uyghur Forced Labor Prevention Act (“UFLPA”).  The UFLPA, signed by President Biden on December 23, 2021, creates a rebuttable presumption that goods manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region (“Xinjiang”) or produced by an entity on a number of lists to be produced, will be denied entry into the U.S. under section 307 of the Tariff Act of 1930 (19 U.S.C. 1307).  The UFLPA was passed in response to the alleged use of forced labor of Uyghurs, Kazakhs, Kyrgyz, Tibetans, and other persecuted groups in China.  Readers can learn more about the UFLPA and the rebuttable presumption, which goes into effect on June 21, 2022, in our previous post following the UFLPA’s enactment.
Continue Reading DHS Requests Comments to Inform Implementation of the Uyghur Forced Labor Prevention Act

On December 23, 2021 President Biden signed H.R. 6256, wide-reaching legislation aimed at preventing the importation of goods “mined, produced or manufactured wholly or in part with forced labor” from China, in particular the Xinjiang Uyghur Autonomous Region (the “XUAR”).  See Text – H.R.6256 – 117th Congress (2021-2022): To ensure that goods made with forced labor in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China do not enter the United States market, and for other purposes. | Congress.gov | Library of Congress.  The bill specifically references cotton, tomatoes and polysilicon, but in fact covers all types of products as well as manufacturers and even companies involved in the recruitment and transport of workers.
Continue Reading President Biden Signs Wide-Reaching Legislation Targeting Goods Allegedly Involving Forced Labor from China

Earlier this month, the US Government updated its ongoing response to what the Department of Commerce (“Commerce”) described as “Beijing’s campaign of repression, mass detention, and high-technology surveillance against Uyghurs,
Continue Reading U.S. Adds Chinese Entities to BIS Entity List and Updates Xinjiang Supply Chain Business Advisory

The Biden Administration has taken new actions related to forced labor in the Xinjiang region that may affect the supply for material critical for solar panels: U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO), the Department of Commerce (Commerce) updated its Entity List, and the Department of Labor (Labor) updated its “List of Goods Produced by Child Labor or Forced Labor.”  These updates are part of an increased emphasis on both forced labor issues and a crackdown on goods from China’s Xinjiang province, and come on the heels of the G7 Summit that was held in mid-June.  The White House indicated that the Administration’s actions are a “translation” of the commitments made at the G7 denouncing forced labor in the Xinjiang region.
Continue Reading Biden Administration’s Recent Actions Related to Products from China’s Xinjiang Region