GOVERNMENT MANDATES will impose new responsibilities on many supply chains in 2024. Rules and regulations concerning the environment, human rights, and drug safety will either take effect this year or gain new provisions. To comply, companies will have to capture and process a great deal of data. Here are four sets of rules and regulations likely to make some of the biggest impact on supply chains in 2024.
with the UFLPA, the government can seize the goods. Even if CBP ultimately clears the import, a shipper that can’t make its case quickly will suffer. “It’s costly for companies, every single day, to hold their goods until they’re able to provide that evidence,” Wallisch says. A company needs to lay the groundwork for UFLPA compliance long before goods go on the water. “First, become educated on what the forced labor requirements are,” suggests Peck. “Then include those as part of your corporate ESG [environmental, social, and corporate governance] program.” Next, analyze overseas suppliers and their products to determine which ones might pose a risk under UFLPA. When you identify such a product, you need to trace it back to its raw materials, gathering proof that there’s no forced labor in the supply chain. “You have to assume that your shipment will be selected for detention and have that rebuttable evidence prepared in advance of the importation,” Peck says. Some of the evidence may come from publicly-available sources such as news articles, reports from non-governmental organizations, and corporate tax records. A shipper should also press suppliers
1. Uyghur Forced Labor Prevention Act Under the Uyghur Forced Labor
risk, the importer must prove that the product doesn’t involve forced labor. “It’s called rebuttable presumption; it’s like guilty until proven innocent,” says Jerry Peck, vice president of product strategy at QAD, a supply chain solutions provider based in California. High-risk products include: items that contain certain industrial metals; clothing and apparel; industrial and consumer electronics; automotive parts; and construction and building materials, among others, according to a document published by QAD. And just because a supplier isn’t based in Xiangjiang, or anywhere at all in China, doesn’t mean the import is safe. “Transshipments come out of China, and go into Malaysia, Thailand, and other countries where they produce the finished goods,” says Peck. Shipments from those countries could also draw scrutiny. If CBP detains a shipment and the importer can’t prove that it complies
Prevention Act (UFLPA), which U.S. Customs and Border Protection (CBP) started to enforce in 2022, companies may not import into the United States any products with content made by forced labor in China’s Xinjiang province, or products sourced from companies with links to forced labor there. While the UFLPA is about two years old, CBP keeps expanding its list of companies associated with forced labor, and it keeps sharpening its focus on certain products. “Going into 2024, I see more fixation on the different sectors within electronics,” says Jamie Wallisch, regulatory and sustainability expert at Assent, an Ottawa-based global firm that helps manufacturers use data to comply with supply chain regulations. When a company imports a product with materials that CBP considers high
26 Inbound Logistics • March 2024
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