Workshop A — Proving Source of Origin Under the UFLPA — What Supply Chain and Compliance Specialists Need to Know to Ensure Compliance Amid Anticipated Ramped-Up Enforcement

Nov 7, 2022 9:00am – 12:30pm

Nicole Bivens Collinson
President, International Trade & Government Relations
Sandler, Travis, & Rosenberg, P.A.

Mike DeVitto
Director, Logistics and Trade Compliance
L.L. Bean, Inc.

Amy Magnus
Director, Customs Affairs and Compliance
A.N. Deringer

For importers trying to bring in goods from the XUAR region, CBT’s ramped-up enforcement could mean an unexpected increase in inspections of shipments to determine place of origin. Knowing how to prepare can make all the difference between being delayed and on time. What documentation is needed for importers to demonstrate that goods were not produced in whole or in part in the XUAR region?

  • Supply chain tracing information
  • Evidence pertaining to merchandise or any component thereof
  • Evidence pertaining to miner, producer, or manufacturer
  • Request an exception to the rebuttable presumption
    • Due diligence system information
    • Supply chain tracing information
    • Supply chain management measures
  • Commodity-Specific Supply Chain Tracing Documentation
    • Cotton
    • Polysilicon
    • Tomatoes
  • Responding to CBT ramped-up enforcement
    • CF-28s and additional documentation needed for these forms
    • Withhold and Release Orders (WROs) related to China cotton and Xinjiang
    • RASA Questionnaires
      • Transactional
      • Procedural
    • What happens if shipments are detained at the border?
  • HYPOTHETICAL UFLPA COMPLIANCE SCENARIO