What Every Multinational Should Know About … the New CBP Supply Chain Integrity Guidelines

On June 12, 2026, U.S. Customs and Border Protection (CBP) published a new guide intended to help the importing community understand the three principal authorities used to enforce U.S. forced labor import restrictions: 19 U.S.C. § 1307, the Uyghur Forced Labor Prevention Act (UFLPA), and the Countering America’s Adversaries Through Sanctions Act (CAATSA). The guide explains how CBP detains, excludes, or restricts goods suspected of being made with convicted, indentured, or forced labor. It also explains the steps importers should take before importing merchandise into the United States, the types of documentation that may be needed to establish admissibility, and the procedures for seeking release of detained shipments.

This publication reflects a significant shift in CBP’s expectations for importers. Supply chain review for forced labor exposure is no longer merely a best practice for risk mitigation; CBP now makes clear that failure to conduct adequate diligence may constitute a failure to exercise the “reasonable care” required under U.S. customs law, with potentially significant consequences.

At the same time, the updated guidance gives importers greater visibility into CBP’s enforcement framework by consolidating process maps for UFLPA, Withhold Release Order (WRO), Finding, and CAATSA actions into a single resource, providing step-by-step instructions for responding to detentions and exclusions, and including expanded appendices with recommended supply chain documentation, practical due diligence examples, and sample enforcement notices. In that respect, noncompliance with this “guidance” may be cited as evidence that an importer failed to meet reasonable standards for preventing forced labor, human trafficking, or the exploitation of Uyghur labor within its supply chain. CBP’s guide therefore serves as both a warning and a roadmap — and a strong signal of where forced labor enforcement is headed.

To help importers navigate these heightened compliance expectations, we provide below a summary of CBP’s new guidance, along with practical best practices for strengthening forced labor compliance programs. For companies sourcing globally, the message is unmistakable: CBP expects importers to know their supply chains, document them thoroughly, and be prepared to demonstrate that their goods were not made, wholly or in part, with forced labor.

Why This Matters

CBP’s new guidance is significant because it expands both the scope and the reach of the agency’s prior forced labor compliance materials. It replaces the June 13, 2022, UFLPA Operational Guidance for Importers and extends beyond a UFLPA-only focus to address the full range of forced labor authorities enforced by CBP. As a result, importers must now understand not only the UFLPA but also how CBP administers WROs, Findings, and CAATSA-related exclusions.

For multinational importers, this has important implications:

• First, the legal standard is expansive. U.S. law prohibits the importation of goods mined, produced, or manufactured, wholly or in part, with forced labor, convict labor, or indentured labor. The phrase “wholly or in part” is critical: even a minor input, raw material, or upstream component linked to forced labor can render an entire shipment inadmissible.
• Second, CBP now presents all three of its principal forced labor enforcement authorities in a single framework, but each authority operates differently. Under 19 U.S.C. § 1307, CBP may issue a WRO when it has reasonable suspicion that goods were made with forced labor, resulting in detention of the merchandise. If CBP develops probable cause and the Secretary of Homeland Security approves, it may issue a Finding, which can lead to seizure and forfeiture. Under the UFLPA, goods produced wholly or in part in the Xinjiang Uyghur Autonomous Region (XUAR) or by entities on the UFLPA Entity List are subject to a rebuttable presumption that they are prohibited from entry. Under CAATSA, goods produced wholly or in part by North Korean nationals or citizens, anywhere in the world, are likewise presumed to be made with forced labor and may be excluded from entry. Importers therefore must understand not only the substantive prohibitions but also the distinct evidentiary thresholds, procedures, and consequences associated with each authority.
• Third, rebutting these presumptions or overcoming CBP action can be demanding. In the UFLPA context, importers seeking release must satisfy a clear and convincing evidence standard and demonstrate compliance with the UFLPA Strategy. In WRO and Finding matters, importers may need to provide documentation sufficient to establish that the goods were not made with forced labor or are otherwise admissible. The practical result is that forced labor compliance requires robust supply chain mapping, traceability, and documentation well before goods reach a U.S. port.
• Fourth, the response timelines are short. For UFLPA detentions, importers generally have 30 days to respond, although limited extensions may be available. For WRO detentions, importers generally have three months to establish admissibility. For exclusions, importers generally have 180 days to file a protest. If a company begins assembling supply chain evidence only after receiving a detention or exclusion notice, it may already be at a significant disadvantage.

To help with understanding the overall process, one of the most practical additions in CBP’s updated guidance is a set of process maps that walk importers through the agency’s principal forced labor enforcement pathways step by step. Rather than describing the authorities only at a high level, the guidance lays out what type of information may trigger CBP action; whether the likely result is detention, exclusion, or seizure; what deadlines govern an importer’s response; and what procedural options may remain available.

In total, the document maps five distinct processes: UFLPA potential input, UFLPA direct input, CAATSA, WRO, and Finding actions. These process maps are important because they highlight that not all forced labor cases follow the same procedural path. In some cases, CBP may detain goods and allow a short period for the importer to submit evidence supporting admissibility. In others, CBP may exclude goods outright or seize them, leaving the importer with more limited and more time-sensitive options. The guidance also clarifies that different CBP offices play different roles in these cases, including the Forced Labor Division, Ports of Entry, Centers of Excellence and Expertise, and the Forced Labor Portal, through which certain requests must be submitted.

Updating Supply Chain Best Practices in Light of the New CBP Guidance

CBP’s updated guidance demonstrates that forced labor compliance cannot rest on a policy statement alone. It requires a functioning, documented, and auditable compliance system capable of identifying risk, tracing supply chains, preserving evidence, and responding quickly when questions arise. For multinational importers, best practices should include the following:

1. Establish Clear Internal Governance and Escalation Procedures

Forced labor compliance should have defined internal ownership. Companies should assign responsibility across legal, customs compliance, procurement, logistics, supply chain, and social compliance functions, and ensure that those teams understand when and how to escalate concerns.

A workable governance structure should address:

• who is responsible for supplier onboarding and risk review;
• who evaluates documentation supporting country of origin and supply chain traceability;
• who has authority to approve higher-risk sourcing decisions;
• when outside counsel, customs brokers, or other advisors are engaged; and
• how potential forced labor concerns are elevated before goods are shipped or entered.

This is especially important because CBP now frames forced labor diligence as part of the importer’s obligation to exercise reasonable care.

2. Map the Supply Chain to the Raw Material Level

CBP expects importers to understand the full supply chain for imported goods, including components, subcomponents, and raw materials. This means identifying:

• all suppliers and sub-suppliers;
• manufacturers, processors, miners, farms, mills, smelters, refiners, and assembly facilities;
• the role each entity plays;
• the location of each production stage;
• the movement of materials through the supply chain; and
• any corporate or operational relationship among entities in the chain.

For companies sourcing globally, this is critical because risk often enters through indirect suppliers. A low-risk final assembly location does not eliminate exposure if an upstream input was sourced from a prohibited region, listed entity, or high-risk labor program.

3. Screen Suppliers, Facilities, and Inputs for Forced Labor, Human Trafficking, and UFLPA Risk

Importers should implement a screening process that goes beyond the immediate vendor. Suppliers, sub-suppliers, production sites, labor brokers, and key inputs should be reviewed against the UFLPA Entity List, CBP’s WROs and Findings, and other relevant government restrictions, advisories, or forced labor indicators.

Screening should also account for:

• aliases and affiliated entities;
• changes in ownership or sourcing patterns;
• known high-risk geographies or labor transfer programs; and
• inconsistencies between claimed origin and available commercial records.

Because supply chains evolve, screening should be repeated periodically and updated when suppliers, manufacturing locations, or source materials change.

4. Maintain Complete Transaction, Production, and Transportation Records

CBP repeatedly emphasizes that importers should be able to support their claims with ordinary-course business records. The specific documents required will vary by product and industry, but common and useful records may include:

• purchase orders and invoices;
• bills of materials and bills of lading;
• shipping, production, and inventory records;
• proofs of payment;
• certificates of origin;
• supplier affidavits and declarations;
• manufacturing flowcharts showing each production step and the responsible entity;
• factory capacity and production records; and
• import and export records.

These records should connect logically from raw material to finished good. Gaps, inconsistencies, or unexplained breaks in the paper trail can undermine an admissibility submission, even where much of the supply chain is otherwise documented.

5. Apply Enhanced Diligence to High-Risk Sectors and Products

CBP applies a risk-based approach, and the guidance includes sector-specific documentation expectations for UFLPA high-priority sectors such as apparel, cotton, tomatoes, polysilicon, aluminum, steel, copper, lithium, PVC, caustic soda, red dates, and seafood.

If a company imports goods in these sectors (or products containing these materials) it should expect a higher level of scrutiny and deeper traceability requirements. For example:

• cotton products may require tracing to the bale level;
• apparel may require records from fiber sourcing through garment assembly;
• solar or silica-based products may require tracing back to quartzite or polysilicon inputs;
• metals may require documentation of mining, smelting, refining, casting, and finishing; and
• seafood may require records showing where it was caught, processed, packed, and exported.

The practical lesson is that generic supplier certifications are unlikely to be enough. CBP expects product-specific, transaction-linked, and traceable evidence.

6. Strengthen Supplier Controls and Contractual Protections

The guidance encourages importers to maintain a meaningful social compliance and due diligence system. At a minimum, that system should include:

• supplier codes of conduct prohibiting forced labor;
• contractual representations regarding compliance with U.S. forced labor laws;
• contractual rights to obtain supply chain records and supporting documentation;
• audit rights, including rights to review sub-tier sourcing where appropriate;
• employee and supplier training on forced labor risks and documentation expectations;
• remediation procedures for identified concerns; and
• termination rights where remediation is not possible or suppliers fail to cooperate.

CBP also makes clear that audits must be meaningful. Financial audits, environmental audits, or social audits that do not specifically assess forced labor indicators will generally carry limited value in demonstrating effective risk mitigation.

7. Identify Red Flags and Monitor the Supply Chain on an Ongoing Basis

Forced labor compliance is not a one-time exercise completed at onboarding. Companies should continuously monitor their supply chains for warning signs, including:

• incomplete or inconsistent origin information;
• supplier reluctance to identify sub-suppliers or production sites;
• sudden changes in sourcing routes or manufacturing locations;
• production volumes that appear inconsistent with facility capacity;
• documentation gaps or conflicting records; and
• indications of labor transfer programs, third-party recruitment risks, or unusual workforce arrangements.

When red flags arise, companies should have a documented process for investigation, follow-up, remediation, and, where necessary, suspension or termination of sourcing relationships.

8. Prepare a Detention Response Before a Detention Happens

A multinational importer should have a response plan in place before cargo is stopped. That plan should identify:

• who internally owns the response and communicates with CBP;
• which outside counsel, customs broker, or consultant will assist;
• where supply chain records are stored and how they can be retrieved quickly;
• which suppliers must provide supporting records on short notice;
• whether the company may seek applicability review, exception review, export, or destruction;
• how business confidential information will be identified and protected; and
• how translations will be obtained and validated.

CBP specifically recommends organized submissions, searchable PDFs, English translations, numbered exhibits, and clear labeling. These details may seem administrative, but they can materially affect the speed and effectiveness of CBP’s review.

9. Plan for Post-Entry Risk, Including Redelivery and Prior Disclosure

The guidance also addresses what may happen when forced labor concerns arise after goods have already entered the United States. CBP may issue a Notice of Redelivery requiring the goods to be returned to the port. Failure to comply can lead to liquidated damages and other enforcement consequences, and in more serious cases may expose the goods to seizure-related action.

The guidance also discusses prior disclosure, which may mitigate penalties if an importer voluntarily discloses a violation before the government discovers it. For multinational companies, this underscores the importance of internal reporting channels, prompt investigation of potential issues, and coordination among legal, compliance, and trade functions when supply chain concerns are identified.

For multinational importers, CBP’s new guidance is more than a procedural reference — it is a statement of enforcement priorities and a clear articulation of what the agency now expects as a matter of reasonable care. Companies that import into the United States should view it as a practical compliance framework for identifying forced labor risk, strengthening supply chain due diligence, and preparing to respond quickly and effectively if CBP detains, excludes, or seizes merchandise.

The central takeaway is that forced labor compliance can no longer be treated as a reactive customs issue addressed only when a shipment is stopped at the border. It must be integrated into sourcing, contracting, supplier onboarding, audit practices, recordkeeping, logistics, and entry procedures. Knowing only the immediate seller or manufacturer is no longer enough; CBP expects importers to understand the upstream supply chain, document it in the ordinary course of business, and be able to substantiate admissibility with credible, transaction-specific evidence.

Importers best positioned under this framework will be those that act before enforcement begins, including by mapping supply chains to the raw material level, implementing meaningful supplier controls, maintaining organized documentation, and establishing clear internal escalation and response procedures. In short, CBP has made plain that importers must be prepared not only to manage forced labor risk but to prove that they have done so.