UFLPA Enforcement Prospective Expansion: Aluminum Products

In a recent development, U.S. Customs and Border Protection (CBP) has begun issuing detention notices against aluminum products under the Uyghur Forced Labor Prevention Act (UFLPA).

As you may be aware, the UFLPA prohibits the importation of goods made by forced labor or child labor, with a focus on goods coming from the Xinjiang Uyghur Autonomous Region (XUAR) in China. CBP has recently initiated enforcement efforts against aluminum products and will most likely focus on aluminum automotive commodities and other commodities classified in Chapter 76 (Aluminum and articles thereof).

Companies importing aluminum products, or commodities with aluminum components, should be proactive in ensuring compliance with the UFLPA. This may include conducting due diligence on their supply chain and implementing compliance programs.

It is also important to stay informed of CBP enforcement trends and be prepared to respond to any inquiries or investigations. Being able to provide manufacturing flowcharts, certificates of origin, and purchase orders, production records, and material invoices as far back as possible to the raw material can be helpful in case of any CBP inquiry.

Questions?

For any questions regarding the UFLPA, U.S. CBP’s likely sector expansion to include aluminum products, and how you can strategically prepare, please contact the Maersk Customs Services Trade Compliance team in North America at compliance.mcsi.nam@maersk.com.