CBP Issues New Supply Chain Integrity Guidelines on Forced Labor Enforcement
Multinational importers must reassess supply chains as CBP consolidates enforcement guidance under three forced labor statutes.
On June 12, 2026, U.S. Customs and Border Protection released a guide clarifying how it enforces U.S. import restrictions on goods produced with forced labor. The guidance consolidates three principal authorities: Section 307 of the Tariff Act (19 U.S.C. § 1307), the Uyghur Forced Labor Prevention Act (UFLPA), and the Countering America's Adversaries Through Sanctions Act (CAATSA). CBP's framework signals heightened scrutiny of supply chains, particularly those with ties to Xinjiang and other high-risk regions. Importers should expect increased detention rates, expanded use of withhold release orders, and more rigorous documentation demands. Companies should map tier-2 and tier-3 suppliers, audit labor practices, and prepare due-diligence records demonstrating that inputs are fully divorced from forced labor sources to mitigate detention and seizure risk.