A request by the Canadian government for feedback on how to strengthen its ability to shut out goods made from forced labor, as part of its trade obligations, has resulted in a blunt rejoinder from a consortium of American trade groups about issues it says have hobbled Customs and Border Protection (CBP) enforcement actions stateside, chiefly by limiting the ability of importers to be “fully effective partners.”
The response by the American Apparel & Footwear Association, the Retail Industry Leaders Association, the National Retail Federation and the United States Fashion Industry Association, as members of the Joint Association Forced Labor Working Group, throws into relief a longstanding question about how much regulation is too much regulation, especially for an industry unused to guardrails.
“Our associations, and the companies we represent, do not tolerate the use of forced labor or other human rights abuses within our supply chains,” the trade groups wrote in a letter to Canadian international trade minister Mary Ng last month. “Our members have spent years, and in many cases decades, working to identify, eradicate and prevent forced labor in their supply chains.”
...“We understand that there may be constraints in sharing information believed to be law enforcement sensitive; however, having a mechanism that would enable the sharing of this information would give importers the ability to incorporate the information into their future due diligence and amplify enforcement going forward,” the trade groups wrote. “Sharing this critical information reduces the burden for the importer to focus on the problematic part of the shipment, as well as reduces the burden on CBP to evaluate only the problematic part of the supply chain instead of the entirety of the supply chain.”