The use of “rebuttable presumption” and detention orders by United States Customs and Border Protection (CBP) to enforce import laws prohibiting the use of forced labour in multiple countries, has only just begun. To say this caught importers flat footed would be an understatement. What have we learned?
- Supplier tracing executed in response to a detention order is not strategic, not fast enough and expensive!
- Social/ethical audits reports of upstream suppliers are not available to submit to CBP.
- CBP believes most social audit programs lack independence and credibility
- Tier One suppliers are confused.
- Most brands lack a strategic plan to engage upstream suppliers once traced.
- CBP’s efforts will be emulated by other countries in the coming year(s).
Join us for a detailed, nuts-n-bolts webinar with HAP Int’l – experts in assisting companies with WRO response, reporting, and strategy – where we will explore:
- CBP enforcement priorities and trends based on actual experience and observations
- Detention response mechanics.
- Alternative, but realistic strategies to engage upstream suppliers in a way that meets the evolving expectations of CBP and other regulators enacting mandatory Human Rights Due Diligence (mHRDD) laws.