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CBP Adds New Forced Labor Benefits to CTPAT Trade Compliance Program

On November 18, 2022, Customs Trade Partnership Against Terrorism (CTPAT) director Manual Garza announced that Customs and Border Protection (CBP) added three new forced labor benefits for its trade compliance partners “to the greatest extent possible and practical effective immediately.”  These benefits include:

  • Front of the Line Admissibility Review: CTPAT trade compliance members who have their shipments detained due to forced labor will have their admissibility packaged prioritized for review by the appropriate Center of Excellence and Expertise. To avail itself of the benefit, the importer must assert that it is a CTPAT member and request prioritized review at the time that supporting documentation is submitted to CBP.
  • Redelivery Hold: CTPAT members whose shipments have been held due to ties to forced labor, where redelivery is normally requested, may hold their shipments at their facility until an admissibility determination is made or until such time as a physical inspection is required. 
  • Detained Withhold Release Order Shipments Move to Bonded Facility: CTPAT members whose shipments have been detained by CBP due to a withhold release order will be allowed to move their goods to a bonded facility to be held until such time that an admissibility determination by CBP is made.

CBP’s announcement follows its addition of six new forced labor requirements to its CTPAT trade compliance program in August 2022.  These requirements include risk-based mapping, code of conduct, evidence of implementation, due diligence and training, remediation planning and sharing of best practices.  These requirements are detailed in the CTPAT Trade Compliance Handbook.

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