The US Government has increased its efforts to prevent goods produced wholly or in part by forced labor from entering the United States. This has taken the form of legislative action through the passage of the Uyghur Forced Labor Prevention Act (UFLPA) and procedural actions like the use of Withhold Release Orders (WROs). As a natural extension, CBP has also enhanced forced labor requirements in the CTPAT Program.
This requirement follows the integration of the Importer Self-Assessment program into CTPAT, branded as ‘CTPAT Trade Compliance’ and requiring applicants to be existing CTPAT Security members.
CBP currently recommends that CTPAT Security members have a documented social compliance plan that addresses how the company ensures that goods imported into the United States are not wholly or partly produced by prohibited forms of labor. On January 1, 2023, the forced labor Minimum Security Criteria will shift from a recommendation to a requirement. CTPAT Security Members will be required to upload evidence of implementation when submitting their annual CTPAT Security Profile or going through a re-validation.
In addition, there are additional, more specific, program requirements for CTPAT Trade Compliance members. These include:
- Risk Based Mapping
- Code of Conduct
- Evidence of Implementation
- Due Diligence and Training
- Remediation Plan
- Shared Best Practices and Path Forward.
Integration of forced labor requirements within CTPAT, as well as the adoption of the CTPAT Trade Compliance model, provide companies with the opportunity to enhance their social and trade compliance programs to reap the benefits of the CTPAT program. Tradewin can help with that. We provide a broad range of CTPAT and Forced Labor requirements, including risk assessments, annual validations, supplier training, and written procedures and manuals.
