U.S. CBP issues comprehensive forced labor enforcement operational guidance for importers

On June 9, 2026, U.S. Customs and Border Protection published its Forced Labor Enforcement Operational Guidance for Importers (CBP Publication No. 5560-0526). 

The guidance supersedes CBP’s prior June 13, 2022, operational guidance, which was limited to the Uyghur Forced Labor Prevention Act. 

This new, expanded 79-page guidance consolidates CBP’s enforcement framework under three distinct legal authorities — the UFLPA, the Countering America’s Adversaries Through Sanctions Act, and the general forced labor import prohibition under 19 U.S.C. § 1307 (implemented through Withhold Release Orders and Findings) — into a single comprehensive resource for the trade community.

Our client briefing provides: 

• background on the legal authorities at issue;
• key highlights of the guidance; and
• recommended implementation steps. 

Importers across all sectors—particularly those sourcing from China or relying on supply chains with exposure to North Korean labor—should review the guidance carefully and assess the adequacy of their existing compliance programs in light of its requirements.

For more information, see our client briefing.