Tag Archives: Supply Chain Transparency

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

FLETF Released Strategy Guidance. Join SPB Webinar To Learn More!

Christmas came early this year.  Ok, not really, but the Department of Homeland Security, which chairs the Forced Labor Enforcement Task Force (FLETF) released its strategy guidance on the Uyghur Forced Labor Prevention Act on June 17, 2022—four days ahead of schedule.  Click here to view FLETF’s strategy guidance. SPB will be hosting a webinar … Continue Reading

CBP Issues Operational Importer Guidance Relating to UFLPA

Late Monday, June 13, 2022, Customs and Border Protection (CBP) issued its long-anticipated Operational Importer Guidance to guide importers before the Uyghur Forced Labor Prevention Act (UFLPA) enters into effect on June 21. As a reminder, beginning on that date, CBP will apply a rebuttable presumption that goods coming from the Xinjiang region violate a … 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

“Is Your Organization Complying With the US Uyghur Forced Labor Prevention Act?” 

The Uyghur Forced Labor Prevention Act goes into effect on June 21, 2022.  The Act creates a rebuttable presumption that “any goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China” (or by an entity included on a list required … 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

Raw Material Surcharges Again on the Cartel Radar – German Authority Raids Cable Companies

In one of the first dawn raids of the New Year, the German competition authority have raided the premises of several cable manufacturers. The investigation arose in response to alleged coordination of metal surcharge calculations. Metal and other raw material surcharges are used in many industries, in addition to the negotiated price, to allow for short-term … 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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