US CUSTOMS PROPOSES TO REQUIRE A SOCIAL COMPLIANCE PROGRAMME AS PART OF C-TPAT CARGO SECURITY PROGRAMME

On 1st April, Arent Fox LLP published an article saying that US Customs and Border Protection is proposing to compel members of the Customs Trade Partnership Against Terrorism (C-TPAT) to maintain a social compliance programme to help combat forced labour in supply chains.  The Tariff Act 1930 prohibits the importation of merchandise mined, produced or manufactured, wholly or in part, in any foreign country by forced or indentured child labour – including forced child labour.  Furthermore, the Countering America’s Adversaries Through Sanctions Act 2017 established a presumption that when there is credible information that goods are produced through the use of North Korean labour, such labour should be considered forced labour, regardless of where the labour is located.  The article says that CBP would require a specific social compliance monitoring system using established US Department of Labor guidelines – an “integrated set of policies and practices through which a company seeks to ensure maximum adherence to the elements of its code of conduct that cover social and labor issues”.  The article lists the relevant criteria.

https://www.arentfox.com/perspectives/alerts/customs-and-border-protection-proposes-require-social-compliance-program-part

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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