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CBP is focusing more intently on imports shipped from China containing cotton from the Xinjiang Uyghur Autonomous Region (XUAR) now that the Uyghur Forced Labor Prevention Act is in effect.  Please note that CBP can question or detain your product even if your supplier or manufacturer is not located in the XUAR.  We recommend that you continue take steps to ensure your supply chain is free of forced labor at every stage. As a practical point, you cannot rely solely on your supplier’s or manufacturer’s statement that they do not use Forced Labor.

For ease of reference, here again is the link to CBP’s guidance on the issue:

While CBP has not definitively stated what level of “evidence” is “clear and convincing,”(which is the standard that must be met) pages 14-15 of the Guidance bullet-point the documents that CBP expects to see.  If you have any questions, feel free to contact Meeks, Sheppard, Leo & Pillsbury at our New York office ( or our Southern California office ( and