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In case there was any doubt as to where the Biden administration stands on forced labor enforcement, United States Customs and Border Protection (CBP) stated recently that its “message to the trade community is clear: Know your supply chains.” This renewed message comes amid the release of new CBP enforcement guidance and an ever-sharpening focus both in Washington and the capitals of many of the United States’ top trade partners on restricting imports from China’s Xinjiang Uighur Autonomous Region. Below is the latest.
New CBP Guidance
As explained in our previous client alert, Section 307 of the Tariff Act of 1930 (19 U.S.C. § 1307) prohibits the importation of merchandise mined, produced or manufactured, wholly or in part, in any foreign country by forced or indentured labor and since 2016, CBP has ramped up its enforcement. Most recently, on January 13, 2021, CBP issued a withhold/release order (WRO)
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