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Forced Labor

Call 305-456-3830 or email info@diaztradelaw.com.

CBP Launches New Forced Labor Portal 

On January 21, 2026, Customs and Border Protection (CBP) launched its new Forced Labor Portal. The Portal provides a central system for submitting review requests for shipments detained or excluded for forced labor enforcement.

Effective, January 21, 2026, importers MUST use the portal to submit the following for review:

  • Withhold Release Order/Finding admissibility reviews.
  • Uyghur Forced Labor Prevention Act applicability reviews.
  • Uyghur Forced Labor Prevention Act requests for exception; and
  • Countering America’s Adversaries Through Sanctions Act exception requests.

All detained or excluded shipments requiring review must be submitted through this Portal, and users must have a login.gov account to access it. Depending on the type of review submitted, submission will be reviewed by CBP personnel in Forced Labor Division, or Port of Entry, or the Center of Excellence and Expertise.

Diaz Trade Law has confirmed with CBP that responses to CBP Form 28 (Request for Information) and CBP Form 29 (Notice of Action) should not be submitted through the Forced Labor Portal.

The Portal is available at https://flportal.cbp.gov/s/login/ and CBP has provided an instructional video on how to submit a request here.

This change reflects another step forward in how CBP interacts with the trade community, transitioning from […]

By |2026-01-29T08:26:11-05:00January 29, 2026|Enforcement, Forced Labor, Import, news, U.S. Customs and Border Protection (CBP)|0 Comments
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New WRO Issued Against Goods Made in Mauritius by Firemount Group

U.S. Customs and Border Protection (CBP) issued a  Withhold Release Order (WRO) against imports made in Mauritius by manufacturer Firemount Group Ltd. (Firemount) after an investigation indicated forced labor use. This WRO was the fourth issued in 2025. CBP now oversees and enforces 54 WROs and nine Findings.

What Happened

On November 18, 2025, CBP issued the WRO against garments, apparel, and textiles manufactured in Mauritius by Firemount. CBP will immediately detain imports subject to the Order. The WRO was issued based on information that reasonably indicates forced labor was used in violation of 19 U.S.C. §1307.

In making this determination, CBP conducted an investigation and analyzed supporting evidence, including interview questionnaires, audio recordings and transcripts, open-source reports from nongovernmental organizations, news media, and academic research.  

The evidence demonstrated that Firemount workers are subject to four International Labour Organization indicators of forced labor: abuse of vulnerability, debt bondage, deception, intimidation, and threats. 

WRO Background 

The strategic use of WROs by CBP has been especially effective at identifying certain nations, industries, and companies that employ forced labor. CBP issues WROs after receiving information that reasonably indicates the use of prison or forced labor at any point in an imported product’s supply chain. Before the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), the United States had only implemented 30 WROs in the previous five decades. […]

By |2025-12-01T10:04:19-05:00December 1, 2025|Enforcement, Forced Labor, Import, International Trade, U.S. Customs and Border Protection (CBP)|0 Comments
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DHS Adds Additional UFLPA High-Priority Sectors; Releases UFLPA 2025 Strategy Update

Learn more about this update and all things UFLPA at our upcoming forced labor webinar on Sept. 17, 2025. Register here.

On August 19, 2024, the U.S. Department of Homeland Security (DHS) announced that it would be adding steel, copper, lithium, caustic soda, and red dates to the list of high-priority sectors for enforcement under the Uyghur Forced Labor Prevention Act (UFLPA). DHS also announced the release of an update to the UFLPA enforcement strategy.

Addition of High-Priority Sectors

Under the UFLPA, DHS is tasked with identifying high-priority sectors for enforcement. A high-priority sector designation indicates that entities in the sector have a higher risk of forced labor or state labor transfer of Uyghurs and other ethnic minorities from Xinjiang. 

In making the announcement of additional sectors, DHS cited each new addition’s connections to forced labor risks. For example, DHS stated that steel and copper have both been government-backed investment focal points in Xinjiang. Similarly, lithium is a government-identified key sector for investment and development in Xinjiang.

UFLPA Enforcement Strategy Update

DHS serves as the chair of the Forced Labor Enforcement Task Force (FLETF). Each year, the task force updates the UFLPA’s Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China (UFLPA Strategy). The task force is statutorily required to provide annual updates […]

By |2025-08-22T11:15:23-04:00August 22, 2025|Enforcement, Forced Labor, Import, International Trade, Supply Chain, U.S Department of Homeland Security (DHS), U.S. Customs and Border Protection (CBP)|0 Comments
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Breaking the Chains: Forced Labor in Mexico’s Supply Chains

Forced labor is a severe violation of human rights and a persistent global issue affecting millions of individuals. According to the ILO, 27.6 million men, women, and children are in forced labor globally.[1] Over $236 billion USD is generated in illegal profits using forced labor every year.[2]

Both Mexico and the United States have robust legal frameworks to eradicate the use of forced labor and have made great strides in detection and enforcement. However, the secretive nature of the forced labor industry, changing bad actor tactics, and the intensive resourcing required presents challenges to both countries.

Forced Labor in Mexico

While Mexico has made great strides in identifying and preventing forced labor, it is still a problem that impacts hundreds of thousands of citizens. Certain risk factors[3] may make certain individuals more vulnerable to forced labor than others, including:

  • Poverty
  • Unstable immigration status
  • Language barriers
  • Lack of social support systems
  • Physical or developmental disabilities

An estimated 850,000 people are still living in modern slavery today in Mexico.[4] The Department of Labor has identified a list of goods it has reason to believe are produced using child labor and forced labor in Mexico including[5]:

  • Beans
  • Cattle
  • Chile peppers
  • Coffee
  • Cucumbers
  • Eggplants
  • Garments
  • Leather goods/accessories
  • Melons
  • Onions
  • Poppies
  • Pornography
  • Sugarcane
  • Tobacco
  • Tomatoes

Investigations have also uncovered severe forms of child labor including using children in the production and trafficking of drugs and in dangerous agricultural work.[6]

Mexico Efforts to Eliminate Forced Labor in Mexico

Over the […]

By |2025-06-25T16:24:22-04:00June 25, 2025|Countries, Forced Labor, Mexico|0 Comments
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DHS Announces New High Priority Sectors for UFLPA Enforcement

The Department of Homeland Security’s (DHS) Forced Labor Enforcement Task Force (FLETF) released an update to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China.

Strategy Background

DHS released the first publication of the UFLPA Strategy in June 2022. The strategy outlines a multi-pronged approach to combating forced labor in global supply chains.The strategy includes a comprehensive assessment of the risk of importing goods with forced labor in the PRC, high priority sectors for enforcement, guidance to importers, recommendations to accurately identify affected goods, and more. DHS released the first update to the publication in August of 2023.

The Latest Update  

The update builds on two years of the Administration’s enforcement of the UFLPA. The latest strategy identified new high priority sectors for enforcement – aluminum, polyvinyl chloride (PVC), and seafood. These industries were identified due to higher risk of forced labor or state labor transfer of Uyghurs and other ethnic minorities from the Xinjiang Uyghur Autonomous Region (XUAR).

Entities in these sectors will now be prioritized for review for enforcement actions such as inclusion on the UFLPA Entity List, sanctions, export limitations, and visa restrictions.

Other products previously identified as high priority such as apparel, cotton and cotton products, silica-based products including polysilicon, and tomatoes remain high priority sectors.

The latest updates also outline how the FLETF has significantly advanced their objectives through several initiatives, such as strong enforcement by U.S. Customs and Border Protection (CBP); expansion of the UFLPA Entity List; […]

By |2024-07-11T10:48:09-04:00July 11, 2024|China, Forced Labor, Import, U.S Department of Homeland Security (DHS), U.S. Customs and Border Protection (CBP)|0 Comments
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