U.S. CBP Proposes Forced Labor to be Part of CTPAT

U.S. CBP Proposes Forced Labor to be Part of CTPAT

U.S. Customs and Border Protection Field Operations has proposed the addition of a Forced Labor component to CTPAT. It will require companies to "develop, implement, and verify a robust social compliance program" in order to take advantage of the program benefits. Approval of the proposal will be recommended by the governing board.

CTPAT participants will be required to meet the seven facets of a successful program:

  • Engage stakeholders and partners
  • Assess risks and impacts
  • Develop code of conduct 
  • Communicate and train
  • Monitor compliance
  • Remediate violations
  • Disclosure 

USCBP Field Operations has also proposed benefits to companies that add this component. These are to include:

  • Prior notice from CBP of violative companies / products before issuing hold release orders. Giving companies time to prepare exculpatory evidence before a WRO takes effect.
  •  Second, priority in line for verification of evidence provided so that an importer can exonerate itself quickly. 
    Third, a reduction in post entry inquiries. 
  • Fourth, if evidence of specific actionable information against the importer is lacking the participant will be excluded from the universe of imports considered high risk. 

Failure to fulfill the terms of the CTPAT TC Memorandum will constitute grounds for removal from the CTPAT program.

If you have CTPAT issues or questions, please contact the DSV Customs Brokerage team. 

Read about how CTPAT works 
CTPAT minimum security criteria and guidelines
Learn more about DSV