The Senate has given final congressional approval to HR 6256, a bipartisan measure that creates a rebuttable presumption that goods from or containing materials from China’s Xinjiang Uyghur Autonomous Region (XUAR), or produced by entities to be listed, are prohibited from importation unless certain conditions are met. The Uyghur Forced Labor Prevention Act seeks to hold China accountable for the repression of the predominantly Muslim Uyghur minority in the region, and to garner support for similar actions by other countries. The White House has indicated that Biden will sign HR 6252 into law. China has indicated that it will retaliate.
HR 6256 increases the need for importers to understand their supply chain, especially if items may be produced in the XUAR or contain items produced in the XUAR. While we await the publication of guidances from CBP, we anticipate that processes and procedures to be used will resemble, in part, those needed to examine supply chains for the presence of conflict minerals, or the procedures deployed to participate in the Customs-Trade Partnership Against Terrorism (C-TPAT). Importers are encouraged to review their social compliance programs and the information already published by CBP, see Forced Labor | U.S. Customs and Border Protection (cbp.gov), and monitor any actions that the People’s Republic of China may take in retaliation.
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