Governments around the world are encouraging companies to embed corporate responsibility, ESG and human rights into their supply chains. Following the release of the Uyghur Forced Labor Prevention Act (“UFLPA”), the U.S. Customs and Border Protection (“CBP”) has revised the voluntary Customs Trade Partnership Against Terrorism (“CTPAT”) Security and \Trade Compliance programs to include forced labor due diligence requirements.
An important requirement of the new program is for participating organizations in the CTPAT Trade Compliance program to conduct a risk-based business mapping of the supply chains and partners that the importer feels pose the most risk for forced labor. Participants have until August 2023 for full implementation of the program, making time of the essence.
One of the toughest challenges businesses will face is getting accurate and real-time visibility into their multi-tier supply chains. Understanding the extent of the multi-tier supplier network, where their sub-tier suppliers are, and what they provide is an overwhelming and nearly impossible challenge when done manually or via surveys.
Everstream combines AI predictions, historical supplier analysis, and frequently updated supplier watch lists with expert human analysis, to dynamically assess and present your overall supplier compliance risk so you can build a responsible and sustainable supplier network.
In exchange for these new measures, CBP offers CTPAT Trade Compliance members three benefits related to forced labor compliance procedures:
- Front of the Line Admissibility Review: CTPAT Trade Compliance partners who have shipments detained due to forced labor will have their admissibility packages prioritized for review by the appropriate Center of Excellence and Expertise (Center).
- Redelivery Hold: CTPAT Trade Compliance partners who have shipments arrive at their facility that are later determined to be held due to ties to forced labor, where redelivery is normally requested, may hold the shipments at their facility, rather than redelivering the goods to CBP, until an admissibility determination is made or until a physical inspection is required.
- Detained Withhold Release Order Shipments Move to Bonded Facility: CTPAT Trade Compliance partners that have a shipment detained by CBP due to a WRO will be allowed to move the goods to a bonded facility to be held until an admissibility determination is made by CBP.
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