CBP to Shift Focus to Traditional Forced Labor Situations, Official Says

CBP will bolster a number of existing initiatives in the coming months aimed at preventing the import of products made with forced labor, said Katie Woodson, assistant director within the operations and forced labor divisions of CBP's Office of Trade, during a panel on forced labor at last week's Western Cargo Conference.

For starters, expect CBP to increase its issuance of withhold release orders and forced labor findings in the coming year amid a shift toward focusing on more "traditional" forced labor situations, according to Woodson.

The agency also plans to increase its engagement with international partners, such as the EU, which passed forced labor regulations in April, and Mexico and Canada, which are partners with the U.S. through the USMCA (see 2407120015).

With USMCA, "we don't want this to be a corridor. Shipments that we exclude from the U.S. [going] to Mexico [instead]. Again, it defeats the purpose of stopping forced labor," Woodson said (see 2407030052).

As CBP shifts its focus on forced labor beyond the Uyghur Forced Labor Prevention Act, it expects to modify guidance that's on CBP's website on what importers should expect if their imports are stopped, and it will be seeking feedback from traders as it makes these modifications, Woodson continued. The agency also plans to modify guidance related to the standards that companies must meet so that CBP can modify WROs or findings.

Lastly, CBP intends to create a new protest module for the Countering America's Adversaries through Sanctions Act, or CAATSA. The act targets factories that use North Korean forced labor, and it functions similarly to the UFLPA, according to Woodson.

This heightened attention comes as North Korean laborers, particularly those working in seafood factories and in fishing vessels, appear to be working throughout the world and not just in China, she said.

Woodson acknowledged "the difficulties of going through applicability reviews" for UFLPA detentions. She noted that over 300 CBP employees in this past year have undergone training on forced labor enforcement.

"We want to build in the skill sets we have piloted, and we'll be rolling out the new supply chain training for our internal employees as well, so we can build in the skill to conduct these reviews more efficiently and more accurately and uniformly," Woodson said.