Tag Archives: Supply Chain Transparency

Supply Chain Transparency: Updates on UK and EU Provisions on Forced Labour and Modern Slavery

Please contact Hannah Laming, Francesco Liberatore and Francesca Puttock with any questions. Forced labour and modern slavery have been the subject of renewed focus across the UK and EU in recent months. While not changing the fundamental reporting requirements under the UK Modern Slavery Act, new guidance from the UK Home Office in March 2025 offers practical … Continue Reading

CBP Targets Battery Tech for UFLPA Enforcement

Customs and Border Protection (CBP) recently indicated potential increased scrutiny of battery technology under the Uyghur Forced Labor Prevention Act (“UFLPA,” or the “Act”). Although the Act covers essentially all trade touching China’s Xinjiang region, it specifically lists cotton, polysilicon, and tomatoes as high-priority sectors for enforcement. Recent CBP actions indicate battery technologies are also … Continue Reading

DHS Adds Two Entities, Eight Subsidiaries to UFLPA Entity List

On June 12, 2023, the Department of Homeland Security (DHS), on behalf of the Forced Labor Enforcement Task Force (FLETF), published a Notice adding two entities and eight subsidiaries to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, for allegedly working with the government of the People’s Republic of China’s Xinjiang Province to recruit, … Continue Reading

Improving The International Supply Chain Through IPEF

How IPEF Builds On Prior Trade Relationships Negotiated By The Biden Administration: In May 2023, the Biden Administration announced the Indo-Pacific Economic Framework for Prosperity (IPEF), a commitment to improving supply chains between the U.S., and the Indo-Pacific nations of Australia, Brunei, Fiji, India, Indonesia, Japan, Malaysia, New Zealand, the Philippines, Singapore, South Korea, Thailand, … Continue Reading

Postal Code For Chinese Manufacturers To Be Required By U.S. CBP Beginning This Weekend

As part of a continued effort to enforce the Uyghur Forced Labor Prevention Act (UFLPA) and to provide early warning to importers and their representatives that goods may have been produced in the Xinjian Uyghur Autonomous Region (XUAR), U.S. Customs and Border Protection (CBP) will require businesses to provide a valid postal code for Chinese manufacturers … Continue Reading

Proposed Rule Would Require Government Contractors to Disclose Climate-Related Risks

This is a Cross-Post from The Trade Practitioner.  Please contact Karen Harbaugh with any questions. The Biden Administration recently released the Federal Supplier Climate Risks and Resilience Proposed Rule requiring contractors of the federal government to disclose climate-related risks.  Read more on the proposed requirements here.… Continue Reading

DHS Released a Notice on the Addition of Entities to the UFLPA Entity List

On August 4, 2022, the U.S. Department of Homeland Security (DHS), as the Chair of the Forced Labor Enforcement Task Force (FLETF), formally published the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. The Entity list is a consolidated register of the four lists required to be developed and maintained pursuant to Section 2(d)(2)(B) of … Continue Reading

Bipartisan Bill Introduced by Senate relating to Uyghur Human Rights Policy Act of 2020

On August 2, 2022, Senators Bob Menendez (D-New Jersey) and Marco Rubio (R-Florida) introduced the Sanctioning Supporters of Slave Labor Act, legislation that would expand the categories of persons that could be sanctioned under the Uyghur Human Rights Policy Act of 2020 (UHRPA).  Rep. Jim Banks (R-Indiana) filed a companion in the House of Representatives.… Continue Reading

CBP Releases Known Importer Letters and Enforcement Guidance relating to the Uyghur Forced Labor Prevention Act

Earlier this year, U.S. Customs and Border Protection (CBP) released a statement on its website that it would be issuing letters to importers identified as having previously imported merchandise from locations or entities potentially subject to the Uyghur Forced Labor Prevention Act (UFLPA).  Well, CBP stuck to its word and just recently released two sample … Continue Reading

Supply Chain Investigations and Legal Privilege

Regulators worldwide are increasing their demands that manufacturers and retailers know and understand all aspects of their supply chains as they relate to Environmental, Social, and Governance (“ESG”) goals. Keeping the findings, communications, information, and reports generated in connection with supply chain ESG investigations is imperative to ensure full and candid fact-finding and to manage … Continue Reading

Good Corporate Social Practices: A Look at Unilever’s Supply Chain Transparency

The palm oil industry has sometimes been associated with human rights abuses and adverse environmental impacts, including deforestation, soil pollution and erosion, water contamination, and threatening endangered species.  However, meaningful efforts are being made to change that. On February 16, 2018, Unilever shared information about its suppliers and mills in order to provide greater transparency … Continue Reading
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