UPDATE: On November 1, 2022, U.S. Customs and Border Protection (CBP) issued a message announcing that implementation of its Uyghur Forced Labor Prevention Act (UFLPA) Region Alert is postponed until further notice. CBP stated that its Office of Trade “is actively working with impacted users to address concerns” and that a new implementation date will be determined.

Original SmarTrade post of October 27, 2022:

CBP to Require New Customs Entry Data Element for Chinese Goods

U.S. Customs and Border Protection (CBP) announced it is adding a Uyghur Forced Labor Protection Act (UFLPA) “Region Alert” with a new mandatory data element for reporting imports via the Automated Commercial Environment (ACE) system. The UFLPA Region Alert will add new validations that will be performed when the Country of Origin is reported as China for entry and for Manufacturer Identification Code (MID). The new data element will be a required postal code for entries from China. After inputting the postal code, users will receive an error message if the postal code provided is not a valid Chinese postal code. In addition, users will receive a warning message when a Uyghur region postal code has been provided.

While noted for implementation in November 2022, a more formal Information Notice will likely be published by CBP in November with a testing period, followed by a full implementation date in mid-December 2022. This new data element and validation process is intended to assist CBP with the implementation of the UFLPA and screening imports for possible concerns involving forced labor in the importation of any goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of China.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of William L. Matthews** William L. Matthews**

Bill has 40 years of experience in international trade. He assists the group’s lawyers in advising clients on matters regarding customs law, regulations and procedures; antidumping and countervailing duty proceedings; import and export policies; and WTO issues.

**Not licensed to practice law.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.