CBP Publishes 79-Page Unified Forced Labor Guidance — UFLPA, CAATSA, and §1307 Now Consolidated, $3.94B in Enforcement Since 2022

U.S. Customs and Border Protection issued comprehensive Forced Labor Enforcement Operational Guidance for Importers on June 12, superseding the prior 2022 UFLPA guidance. The 79-page document consolidates CBP's enforcement framework under three legal authorities — the Uyghur Forced Labor Prevention Act, the Countering America's Adversaries Through Sanctions Act, and the general forced labor import prohibition under 19 U.S.C. § 1307 — and provides step-by-step instructions on responding to detentions, exclusions, and seizures. Recommended supply chain documentation for high-priority sectors includes cotton, tomatoes, polysilicon, apparel, aluminum, and seafood. As of early 2026, 69,415 shipments valued at $3.94 billion have been subjected to forced labor enforcement actions since the UFLPA took effect in 2022. For trade counsel and supply chain compliance teams advising importers, the consolidated 79-page guidance is the most comprehensive public articulation of CBP's enforcement expectations to date: the consolidation of three legal authorities under a single operational document means that importers who previously understood their UFLPA obligations as the full scope of their exposure are now on notice that CAATSA and §1307 carry parallel and potentially broader enforcement reach. The documentation recommendations for high-priority sectors are the due diligence floor, not a ceiling.