CBP Expands Guidance into Comprehensive Forced Labor Enforcement Manual
June 26, 2026 Update
CBP has released an updated Forced Labor Enforcement Operational Guidance for Importers, replacing its earlier importer guidance with a single, consolidated reference covering all federal forced labor import enforcement authorities.
The updated guidance now includes:
- 19 U.S.C. § 1307 forced labor prohibitions
- Uyghur Forced Labor Prevention Act (UFLPA) enforcement
- Countering America’s Adversaries Through Sanctions Act (CAATSA) requirements
New features include:
- A unified enforcement process map covering UFLPA, Withhold Release Orders (WROs), Findings, and CAATSA actions.
- Dedicated sections explaining detention, exclusion, and enforcement procedures.
- Expanded appendices with recommended supply chain documentation, practical due diligence examples, sample detention and exclusion notices, Notices of Redelivery, and Certificates of Origin.
While the update does not create new enforcement authorities, it gives importers significantly greater transparency into CBP’s enforcement process and serves as a comprehensive compliance resource for organizations managing forced labor risk across their supply chains.
June 22, 2026
CBP Issues Consolidated Operational Guidance
CBP has since released a comprehensive Forced Labor Enforcement Operational Guidance document that consolidates multiple authorities and procedures into a single framework for importers.
The guidance brings together information related to the Uyghur Forced Labor Prevention Act (UFLPA), Withhold Release Orders (WROs), Findings, and other forced labor enforcement mechanisms, providing greater transparency into detention procedures, evidence requirements, and supply chain due diligence expectations.
By consolidating these resources, CBP aims to provide importers with a clearer understanding of compliance obligations and best practices for addressing forced labor risks throughout their supply chains.
Importers should review the updated guidance and evaluate their traceability and documentation processes to ensure they are prepared to respond to potential enforcement actions.
Source: CBP Forced Labor Enforcement Operational Guidance for Importers
https://www.cbp.gov/document/guides/cbp-forced-labor-enforcement-operational-guidance-importers
June 16, 2026
U.S. Customs and Border Protection (CBP) has issued new Forced Labor Enforcement Operational Guidance for Importers, providing a comprehensive overview of how the agency enforces U.S. forced labor laws and what importers should be prepared to provide if their shipments are detained or reviewed.
The approximately 80-page guidance consolidates procedures under:
- 19 U.S.C. §1307
- The Uyghur Forced Labor Prevention Act (UFLPA)
- The Countering America’s Adversaries Through Sanctions Act (CAATSA) related to North Korean forced labor concerns.
Key Takeaways for Importers
The new guidance explains:
- How CBP processes detentions, exclusions, and seizures.
- Differences between UFLPA cases and traditional Withhold Release Orders (WROs).
- Documentation expectations for supply chain traceability.
- Recommended due diligence and supply chain management practices.
- Best practices for submitting information to CBP.
- Additional guidance for high-priority sectors and traceability requirements.
CBP also emphasizes the importance of exercising reasonable care by maintaining visibility throughout the supply chain and retaining records that demonstrate goods were not produced with forced labor. The guidance includes appendices covering traceability documentation, due diligence practices, and isotopic testing methodologies.
Why It Matters
The publication supersedes CBP’s earlier 2022 UFLPA guidance and reflects the agency’s evolving approach to forced labor enforcement. As scrutiny of global supply chains continues to increase, importers should evaluate whether their current documentation and supplier due diligence programs are sufficient to meet CBP expectations.
Need help understanding CBP’s forced labor requirements or preparing for a detention review?
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Our trade compliance specialists can help you navigate evolving regulatory requirements and develop strategies to strengthen your supply chain compliance program.
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Sources
- CBP Forced Labor Enforcement Operational Guidance for Importers:https://www.cbp.gov/document/guides/cbp-forced-labor-enforcement-operational-guidance-importers
