Just a quick entry here, to give an update on some new
developments on this subject, since my first two posts:
Since those posts, a couple key developments tell me this is
a story that has yet to be fully told.
First, on July 27, CBP Commissioner Kerlikowske raised the
matter in his opening remarks to the Commercial Customs Operations Advisory
Committee (COAC)[i]:
“And as you know, enforcement of the nation’s trade laws is
a core mission for CBP, and I want to announce the new Forced Labor Working Group
focusing on this key enforcement priority.
Following the Custom’s Bill’s repeal of the “consumptive
demand” loophole, we have been working with industry, civil society
organizations, and others to rigorously enforce the law and prevent the import
of goods made with forced, convict, or child labor into the United States.”
He further went on to say:
“The role of industry in this issue is clear, and we must
work closely with importers, brokers, and companies who want to do the right
thing to clarify standards for their supply chains.”
I find this second statement very interesting. Is this
hinting at a trusted trader type strategy? Perhaps a CTPAT type model, but
targeting forced labor in supply chains? How about CTPAFL? No, to many letters….
Regardless of my conspiracy theories, this is just further evidence that CBP
has no intention of dropping the matter, whatever their future plans are
exactly.
Another development comes from the private business side.
Recently Descartes’ SPL division “Descartes MK Denied Party Screening” added a
new list type to their offering, called “Customs and Border Protection Forced
Labor”. They explain the list as: “The
manufacturers listed have Withhold Release Orders (WRO) issued by the
Commissioner”.
Descartes MK is a leader in the generation of SPL content[ii]
for automation, such as in SAP GTS, and their inclusion of this content is a
good indication that we can expect to see the list grow.
I’ll keep checking in on this subject, and I encourage
anyone reading this to start the process of a supply chain review for
forced labor. As I mentioned in my last post on the subject, there are other
good reasons to do so.
P.S.: I’m a little surprised that Descartes called the list “…
Forced Labor”. I was really hoping to see “… Forced LaboUr” from a Canadian company, eh! Ok. If you’re not Canadian,
you probably didn’t get that one….
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