US Customs to Require China Factory Postal Code to Ensure Imported Goods Not Made with Forced Labor
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Starting March 18, 2023, all shipments manufactured in China will be required to enter the U.S. with the postal code of the factory. U.S. Customs and Border Protection (CBP) will be validating those imports to ensure the imported goods are not produced in the Xinjiang Uyghur Autonomous Region (XUAR).
The Uyghur Forced Labor Prevention Act (UFLPA) establishes a rebuttable presumption that goods, merchandise, articles, and wares that are produced, manufactured, or mined in whole or in part in Xinjiang are prohibited under 19 U.S.C. § 1307 and are not entitled to entry into the United States. Additionally, any goods manufactured, produced, or mined by entities on the UFLPA Entity List are also subject to this presumption.
Under the UFLPA Region Alert, being deployed March 18, 2023, all entries from China on CBP's Automated Commercial Environment (ACE) system, which CBP uses to collect data on imports into the United States, will go through the following three validations:
- Postal code will be a required field.
- Users will receive an error message if the provided postal code is not a valid Chinese postal code.
- Users will receive a warning message when a postal code associated with the XUAR region is provided.
The ACE system will provide these validations when the manufacturer's country of origin for an entry is the People's Republic of China (CN), CN is selected as the manufacturer's country of origin when a Manufacturer Identification (MID) code is created, and when an existing MID with CN as its country of origin is updated.
Additionally, CBP will not release a list of Chinese postal codes or a list of postal codes in the XUAR as it deploys the UFLPA Region Alert. "Everyone needs to do the due diligence to know" their supply chains, and "part of that due diligence" is the knowledge of where a shipment came from, including the manufacturer's name and address, which includes the postal code, according to Katie Woodson from CBP's Forced Labor Division. If ACE produces a warning message, importers should be aware that the UFPLA will be triggered. Following that, shipments from that manufacturer could be detained.
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