In December 2021, the US enacted the Uyghur Forced Labor Prevention Act (UFLPA) that banned the importation of products into the US where forced labor may have been used during the manufacturing process. Enforcement of the act is particularly aggressive as the mere presumption a product encompasses materials thought to have originated in Xinjiang or by an entity on the UFPLA Entity List can be seized by CBP.
The list of products and parts emanating from the Xinjiang region of China is extensive and includes:
- Solar panels, cells, and modules
- Photovoltaic ingots and wafers
- Lithium-ion batteries and electronics
- Hair products
- Textiles, threads, and yarn
- Toys
- Seafood and produce
- Building materials
- Cotton
Further manufacturing of finished goods may continue elsewhere in other countries – apparel and footwear are often finished in other Southeast Asian countries such as Bangladesh, India, Vietnam, Laos, and Cambodia for example – but if some of the original materials come from Xinjiang, they could be considered suspicious and seized…
Unique combinations of elements within a product can link it to geographic regions around the world, and isotope testing is the methodology used to identify those elements. The methodology is effective even as different products are blended, as is the case with textiles, yarns, and cotton in footwear and apparel manufacturing.
What Can Be Done?
Brands often have clarity on tier 1 and tier 2 suppliers in their supply chains, but with UFLPA necessitating visibility right down to component origins, apparel brands are at serious risk of a product seizure and social media notoriety without more clarity!
Attaining this level of clarity requires much more data on each and every product produced. It can be a daunting task.
Fortunately, there are solutions out there. Services are available that can trace the paper trail of product production to give a clearer picture of component origins.
Alba’s solution goes many steps further by incorporating satellite imagery and other proprietary methodologies to provide an easy-to-understand supply chain risk score. Using the same technology used by CBP, Alba can provide the clearest picture yet of your product and component origins.
Partnering with Alba for your customs brokerage means we’ll already have the majority of the necessary data we need to start the investigation, further simplifying your compliance with the UFLPA. Learn more about our solution here.
Every day, thousands of forced labor violations are carried out uninterrupted throughout the world and within almost every industry. It’s good environment social and governance practice (ESG) to ensure your products and your supply chain are not encouraging the use of forced and child labor, and it can be a brand and cost saver too.
