What Every Multinational Should Know About … the New CBP Supply Chain Integrity Guidelines

Short summary

U.S. Customs and Border Protection published new guidelines consolidating its three principal forced labor enforcement authorities: Section 1307, UFLPA, and CAATSA. The guide signals that inadequate supply chain diligence may now constitute failure to meet 'reasonable care' standards under customs law, with significant consequences for importers. Even minor inputs linked to forced labor can render an entire shipment inadmissible.

• •CBP's new guide consolidates UFLPA, WRO, and CAATSA enforcement frameworks into a single resource
• •Inadequate supply chain diligence may now constitute failure to meet 'reasonable care' under customs law
• •Even minor upstream components linked to forced labor can render entire shipments inadmissible

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