Client Alert: Ten Questions Answered About Implementation of the Uyghur Forced Labor Prevention Act

Can you prove the absence of forced labor in your supply chain? As of June 21, 2022, US Customs and Border Protection (CBP) will presume that all goods manufactured in whole or in part in the Xinjiang Uyghur Autonomous Region of China (Xinjiang) or by certain designated entities are made with forced labor and are therefore barred from entering the United States. At the outset, CBP enforcement will focus on apparel, cotton, silica-based, and tomato products. If CBP bars a shipment from entry, importers will generally have 30 days to prove through clear and convincing evidence that the goods were not made with forced labor. This underscores the importance of supply chain due diligence, tracing, management, and documentation for global companies – particularly those with components of high-risk industries in their supply chains. 

This alert answers ten key questions about how the Uyghur Forced Labor Prevention Act (UFLPA) will work in practice, based on recently-issued guidance from CBP and the Forced Labor Enforcement Task Force (the Taskforce), which developed the strategy to implement the UFLPA.

Read the full alert here.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Client Alert: Ten Questions Answered About Implementation of the Uyghur Forced Labor Prevention Act

Can you prove the absence of forced labor in your supply chain? As of June 21, 2022, US Customs and Border Protection (CBP) will presume that all goods manufactured in whole or in part in the Xinjiang Uyghur Autonomous Region of China (Xinjiang) or by certain designated entities are made with forced labor and are therefore barred from entering the United States. At the outset, CBP enforcement will focus on apparel, cotton, silica-based, and tomato products. If CBP bars a shipment from entry, importers will generally have 30 days to prove through clear and convincing evidence that the goods were not made with forced labor. This underscores the importance of supply chain due diligence, tracing, management, and documentation for global companies – particularly those with components of high-risk industries in their supply chains. 

This alert answers ten key questions about how the Uyghur Forced Labor Prevention Act (UFLPA) will work in practice, based on recently-issued guidance from CBP and the Forced Labor Enforcement Task Force (the Taskforce), which developed the strategy to implement the UFLPA.

Read the full alert here.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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