CBP Releases New CTPAT Alert on Forced Labor
CBP released a new CTPAT Alert on March 22 with information on what Customs Trade Partnership Against Terrorism members need to do to comply with new forced labor requirements in the trusted trader program that took effect Jan. 1.
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“Some of the key elements of a social compliance program are already part of the CTPAT program -- they just need to be expanded to include the threat of forced labor,” CBP said in the alert. “CTPAT Members need to be proactive and take steps” outlined in the report “to be able to document in their security profile that they have done their due diligence to mitigate the risk of forced labor in their supply chains.”
Since Jan. 1, the CTPAT criteria have mandated that members “have a documented social compliance program in place that, at a minimum, addresses how the company ensures goods imported into the United States were not mined, produced or manufactured, wholly or in part,” with prohibited forced labor.
“CTPAT importers, exporters, and foreign manufacturers must include the threat of forced labor -- an illegal activity under U.S. and international law -- into the company’s risk assessment methodology,” the alert said. “And, they must also document how they address this threat through a documented social compliance program -- also referred to as a social responsibility program (or responsible sourcing).”
Programs should include engaging stakeholders and partners, assessing risks and impacts and engaging in “robust communication,” the alert said. Members should “train internally and across your supply chain to ensure understanding,” and require codes of conduct from suppliers. They should allow confidential reporting, include contractual obligations related to forced labor with their first-tier suppliers, monitor compliance by way of targeted audits and proactive worker participation and remediate violations. Optionally, they may also commission independent reviews and report their performance. The alert includes details on each of these aspects of social compliance programs.