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Uyghur Forced Labor Prevention Act

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On July 17, 2023, the U.S. Securities and Exchange Commission (“SEC”) urged Chinese companies to disclose certain business links they may have to Uyghurs and other Muslim minorities. The companies may face compliance risk and supply chain disruptions if they operate in the Xinjiang region of China or do business with companies that operate in the area known for its Uyghur population, the SEC said in new guidance. The Uyghur Forced Labor Prevention Act (“UFLPA”),…

The Uyghur Forced Labor Prevention Act (“UFLPA”) took effect on June 21, 2022, and establishes a rebuttable presumption that all goods mined, produced, or manufactured wholly or in part in Xinjiang, China, or by entities identified on the “UFLPA Entity List,” are made with forced labor and prohibits them from entry into the United States under Section 307 of the Tariff Act of 1930. A few days prior to the implementation of the UFLPA, US…

The potential impact of the Uyghur Forced Labor Prevention Act (“Act”) is sweeping. For companies concerned about potential supply chain disruptions, there is now opportunity to help shape the enforcement strategy required under the Act. On January 24, 2022, the Department of Homeland Security published in the Federal Register a request for public comments. To date, few comments have been submitted. US importers and other interested parties should consider submitting comments that will both inform…