US bans imports from China’s Xinjiang region

Effective June 21, 2022, in an effort to address forced labor concerns, U.S. law will broadly prohibit imports of products from China’s Xinjiang Uyghur Autonomous Region (XUAR), along with additional companies determined to be related to supply from that region.

Companies doing business in China should consider the following to prepare for the new requirements:

• Review your compliance program and supply chain due diligence processes with China and forced labor in mind. Supplier questionnaires should include inquiries about forced labor and human trafficking, as well as detailed information about the origins of raw materials and laborers.

• Examine your supply chains and begin considering alternative suppliers where necessary. A high level of visibility into supply chains is increasingly important for all multinational companies, not only those doing business in China. Prioritize robust information gathering, in-person visits if possible, and comprehensive supply chain mapping.

• Start working with your suppliers now to make sure they organize their operations to foreclose any possible use of forced labor. Implementing measures now within your supply chains, including intermediaries, will help to avoid legal and reputational issues later.

While some of the enforcement specifics of the Uyghur Forced Labor Prevention Act will be clarified over the next six months, it is clear that grand statements from corporations are no longer enough. Companies need to implement robust preventative and transparency measures, with their compliance departments—not their communications departments—leading the way.

You can read more about this topic here, here, and here. 

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