By Jasmin Malik Chua | November 19, 2024

Brian Hoxie, director of the forced labor division at U.S. Customs and Border Protection’s (CBP) Trade Remedy Law Enforcement Directorate, says this so much he isn’t sure if it’s even a joke anymore.

“I like to say that everything seems to be forced labor,” he said at the United States Fashion Industry Association’s Apparel Importers Trade & Transportation Conference in New York City last week. “It’s textiles, it’s de minimis, it’s just taking a pick of what product it is—there’s some kind of connection to forced labor.”


With the Uyghur Forced Labor Prevention Act, or UFLPA, now in its third year of enforcement of targeting goods from China’s Xinjiang region, Tasha Reid Hippolyte, deputy assistant secretary for trade and economic competitiveness at the Department of Homeland Security, feels no small degree of vindication.

“I think there were a lot of skeptics in terms of would we be able to implement it? Would we be able to enforce the rebuttable presumption? Would we be able to even add entities to Entity List, and will we completely just shut down trade?” she said. “So to that, three things: One, we’ve been able to add additional entities; two, we’ve seen an uptick in what CBP has been able to enforce; and three, we have not completely shut down trade. So that’s a really positive thing. And in two years, we’ve learned a lot.”

One of those learnings is that transparency and information sharing are critical to facilitating enforcement, Hippolyte said. So is eradicating some of the pain points that stymie engagement with a priority industry like textiles and apparel. Of the nearly 80 names on the UFLPA Entity List, for instance, half relate to the sector. Continuing to expand that list—and, in time, including items of interest such as Chinese names and physical addresses—will remain important to “reinforce” transparency for the trade community and supply it with the drumbeat of things it’s been asking for, she added.

“It is so important for us to hear where those issues are because we are truly listening,” Hippolyte said, adding that the UFLPA dashboard, which tracks detentions by sector, value and country of origin, arose from some of those conversations.

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