ICAR submission to the Forced Labor Enforcement Task Force on US Uyghur Forced Labor Prevention Act

Comment submission to the Forced Labor Enforcement Task Force, DHS Docket No. DHS-2022-001, on behalf of the International Corporate Accountability Roundtable (ICAR).

The International Corporate Accountability Roundtable (ICAR) is a coalition of 40+ member and  partner organizations committed to ending corporate abuse of people and the planet. To support enforcement of Section 307 of the Tariff Act and the Uyghur Forced Labor Prevention Act  (UFLPA), ICAR urges the U.S. Department of Homeland Security (DHS) and the Forced Labor Enforcement Task Force (FLETF) to require companies that import goods into the United States to accurately trace their supply chains for those goods and report comprehensive supply chain information to Customs and Border Protection (CBP) as a condition of entry.

ICAR comments to express that in order for CBP and other enforcement agencies to accurately identify goods entering the U.S. in violation of the Tariff Act, importers must be required to  accurately trace, document, and report detailed supply chain data to CBP. While this requirement could initially apply to importers of high-risk products under the UFLPA, ultimately CBP should require comprehensive disclosure of supply chain information from all importers. A supply chain disclosure requirement like this would build on other traceability programs like the Seafood Import Monitoring Program (SIMP), which could serve as a model for establishing a system that can effectively pair traceability and enforcement. To further enable enforcement, key supply chain data should be made publicly available.

To continue reading ICAR’s comment submission on the US Uyghur Forced Labor Prevention Act, download the full pdf here.