On June 12, 2026, U.S. Customs and Border Protection (“CBP”), through a Cargo Systems Messaging Service (CSMS) notice, issued a comprehensive new Forced Labor Enforcement Operational Guidance for importers.
The new guidance is an essential resource for importers and trade professionals, offering a single, consolidated overview of the following three primary authorities CBP uses to prevent the importation of goods produced with forced labor from entering the United States:
- 19 U.S.C. § 1307
- Uyghur Forced Labor Prevention Act (“UFLPA”)
- Countering America’s Adversaries Through Sanctions Act (“CAATSA”).
The updated guidance aims to provide importers with significantly greater transparency into CBP’s enforcement landscape. Key enhancements to the guidance include:
- Consolidated Process Maps: New enforcement process maps that cover UFLPA, Withhold Release Orders (WROs), Findings, and CAATSA actions, all within a single document.
- Step-by-Step Instructions on Responding to Exclusions or Detentions: Dedicated sections for the WRO/Finding and CAATSA processes that detail exactly what importers should expect and how to effectively respond to cargo detentions or exclusions.
- Additional Appendices: Covering recommended supply chain documentation for high-priority sectors, real-world examples of UFLPA due diligence, and sample detention and exclusion notices related to UFLPA, WRO and CAATSA as well as Notices of Redelivery and Certificate of Origin.
CBP is strongly encouraging all importers to familiarize themselves with this new guidance and to proactively conduct due diligence on their suppliers prior to importation to ensure compliance with applicable forced labor laws.
If you have any questions about the new operational guidance or navigating forced labor laws, please contact your Husch Blackwell attorney.