Compliant and expedited movement of goods is vitally important to the trade community, and efficient inbound cargo clearance is paramount to the US economy. Delays at the border can threaten business operations through cascading impacts on manufacturing operations, distribution centers, logistics providers, carriers, and vendors, impacting US jobs.
US Customs and Border Protection’s (CBP) current process for the release of goods linked to the forced labor import prohibition (Section 307 of the Tariff Act of 1930, as amended) is opaque for US companies, inhibits an effective process to determine risk of forced labor in the import supply chain, and fails to leverage businesses’ resources to deter offending behavior. We support the prevention, identification, and eradication of forced labor globally. Many companies, including USCIB members, are committed to ensuring that forced labor and other violations of labor rights are not present in their supply chains.
Enforcement needs to be effective and efficient. USCIB has presented to policymakers a multi-step proposal, which includes providing companies information about allegations earlier in the investigation process, providing companies 60 days to respond with information critical to the investigation, and instituting a time-limited process. The proposal seeks to improve CBP’s enforcement process and enhance compliance consistent with the requirements of Section 307, provide increased transparency, and encourage greater collaboration with the trade community. This process would also expedite shipment clearance and promote cooperation with the trade community to eradicate forced labor and provide transparency to an otherwise “black box” of enforcement.
Involving outside stakeholders earlier in the process would enable CBP to proactively address forced labor at its source, prevent the importation of offending goods, streamline document reviews by companies and CBP, more efficiently use CBP resources, and allow companies to take necessary steps that could prevent goods from being detained at the port.