Does Your Import Checklist Consider Use of Forced Labor?

United States Custom House - Philadelphia, Pennsylvania, USA

I recently attended a program sponsored by the French-American Chamber of Commerce at the historic U.S. Customs House in Philadelphia.  The audience came from varied points of view concerning the import of goods into the U.S. The group included representatives from the City’s Dept. of Commerce, Philadelphia International Airport and several companies. The officials from Customs and Border Protection began the morning by allowing us to view the confiscated items in their museum.  These included counterfeit sports jerseys and luxury goods, suspicious pharmaceuticals and a set of brass knuckles.

After the museum visit, we had an opportunity to hear CBP’s perspective on recent import challenges, and the CBP panelists answered questions for the audience.  CBP stressed the importance of properly completing required paperwork and recommended that companies use licensed Customer Brokers to assist with the import process.

The CBP’s current priorities include preventing human trafficking and the import of products made by forced labor (by children, convicts, political refugees, etc.).  All U.S. importers need to be aware of the law concerning and take steps to be in compliance.  “The Uyghur Forced Labor Prevention Act was enacted on December 23, 2021, to strengthen the existing prohibition against the importation of goods made wholly or in part with forced labor into the United States and to end the systematic use of forced labor in the Xinjiang Uyghur Autonomous Region.” (

“Your company should exercise due diligence and closely examine your entire supply chain.  Additional information on effective due diligence may be found in CBP’s UFLPA Operational Guidance for Importers here and in the UFLPA Strategy.” (  If your supply chain includes items from China, it would also be prudent to include Representations concerning your suppliers’ compliance in your contract documents.

By working with an international attorney, you can protect your business from legal and ethical issues, ensure compliance with import laws, and maintain a successful import operation.

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