PVC, Aluminum, and Seafood New Target Sectors for Forced Labor

Jul. 11, 2024
By: Pietro N. Bianchi

The Forced Labor Enforcement Task Force (FLETF) updated its strategy on forced labor, giving importers insight into potential risks. Under the Uyghur Forced Labor Prevention Act (UFLPA), the FLETF is charged with developing a strategy to prevent the importation of goods made with forced labor in China.

Notably in this year’s strategy update, the FLETF identified new high priority sectors for enforcement –polyvinyl chloride (PVC), aluminum, and seafood. This is the first time the FLETF updated the high priority sectors list since 2022. While adding sectors to the high priority list is new, CBP has been targeting these sectors for some time. We previously reported how aluminum was targeted after an NGO reported on forced labor in the motor vehicle supply chain. The FLETF’s updated strategy references how they started focusing on seafood after the Outlaw Ocean Project documented Uyghur workers in several seafood plants in eastern China. Also, we covered how a CBP addendum to notice of detention listed specific instructions for aluminum and PVC detentions at the beginning of 2024.

It is reasonable to expect that CBP will continue to focus on these sectors and that Chinese entities in these sectors will soon be included on the UFLPA Entity List, which CBP has been focusing on lately. Often, it can be too late to address your supply chains if CBP is already looking into suppliers in your sectors. Diligent importers should address supply chain compliance and keep up with trade news and NGO reports, which tend to point Customs in a direction.

Additionally of note, the FLETF’s updated strategy states that “[i]dentification of the new high priority sectors provides transparency to importers and sends a signal to responsible businesses to prioritize scrutiny of supply chains that may involve products in those sectors.” So, it would be prudent for importers of PVC, aluminum, or seafood products to audit their supply chains now if they have not done so already.

If you have questions about supply chain diligence or forced labor do not hesitate to contact an attorney at Barnes Richardson, & Colburn LLP.