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CBP Spokesperson Suggests Companies Pursue Third-Party Audits to Hedge Against Forced Labor

A CBP spokesperson recommended that companies seeking to ensure their supply chains are free of forced labor consider conducting a third-party audit of their supply chain, according to comments supplied by the agency when International Trade Today sought CBP's feedback on recent allegations that outdoor lifestyle retailer REI might have forced labor in its supply chain (see 2501020035).

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The agency spokesperson declined to comment specifically on the allegations against REI that were mentioned in a December report from the Labor Center at the University of Massachusetts Amherst.

However, when asked about advice CBP might be able to provide to companies seeking to ensure that forced labor isn't in their supply chains, the CBP spokesperson said: "CBP recommends that the company conduct an in-depth forced labor audit/assessment of their supply chain by a reputable social compliance auditor that specializes in forced labor to identify the International Labour Organization’s eleven indicators of forced labor, implement a corrective action plan to address identified issues, and conduct a verification audit/assessment to ensure the changes the entity put in place are sufficient to systematically remediate forced labor."

The spokesperson also recommended that companies visit the Department of Labor's Comply Chain application, which outlines critical elements of a social compliance program.

"Businesses and individuals should undertake due diligence to ensure compliance with U.S. law and to identify potential supply chain exposure to companies utilizing forced labor in their supply chains," the spokesperson said.