What the UFLPA and the EU Forced Labour Regulation ask of importers, and how to be ready.
Both laws ask the same simple question: can you show who made your goods, from what, back to the raw material?
It's a fair question, and the answer is a file. Built early and calmly, it's very doable.
The Uyghur Forced Labor Prevention Act presumes that goods made wholly or in part in the Xinjiang region of China, or by listed entities, are made with forced labor, and keeps them out of the country.
An importer can answer that presumption. It takes clear and convincing evidence that the goods weren't made with forced labor, and a supply chain that has been traced. CBP's guidance expects tracing back to the raw material.
The EU Forced Labour Regulation bans products made with forced labour from the EU market. It applies from 14 December 2027. Authorities will take a risk-based approach to deciding where to look, and companies will need to be able to show their supply chain.
People who buy what you sell want to know it was made fairly. Honest factories want to compete on equal terms with factories held to the same rules. A file that answers the question is good for all of them, and for you.
Most suppliers are good. They just haven't been asked for this before.
For each product, a good file holds:
Many chains that moved out of China still depend on inputs from China, so the file follows the inputs, not just the final factory.
The ones with the most volume, or the most exposure, come first.
Who makes each part, and who supplies them, in every country.
face to face. Explain what's needed and why. Most suppliers hand them over once they understand.
with a note of who holds what, and keep it current.
You and your broker and counsel decide strategy, file with CBP and advise on the law.
We build the supplier side: the map, the records and the supplier statements, across China, Vietnam and India, as a system you own and run.
We don't file with CBP, give legal advice or promise an outcome.
The Uyghur Forced Labor Prevention Act is a US law. It presumes that goods made wholly or in part in the Xinjiang region of China, or by entities on a CBP list, are made with forced labor, and it bars them from entry unless the importer can show otherwise.
CBP starts from the presumption that covered goods are barred. The importer can answer it with clear and convincing evidence that the goods weren't made with forced labor, and with a supply chain that has been traced.
It applies to goods with Xinjiang inputs or listed entities in their chain, wherever the final assembly happens. Many chains that moved out of China still depend on inputs from China, so the file has to follow the inputs.
An EU regulation that bans products made with forced labour from the EU market. It applies from 14 December 2027.
A map of the chain down to raw material, purchase records, production records, shipment and payment records, statements from suppliers, and a note of who holds which document.
No. Your customs broker or trade counsel files. We build and organise the supplier-side evidence so they have something solid to work with.
No. We build the supplier side: the records, files and structure. Your customs broker and trade counsel advise and file.
Book a 30-minute meeting. We'll talk about what you make, where, and what you need to prove, then tell you which program fits.
Tell us what you make, where, and who your suppliers are. We'll tell you what we see.