CBP Issuing Forced Labor Questionnaires on Cotton Sourcing, Trade Group Says
CBP recently sent a pair of questionnaires to importers regarding the use of forced labor in supply chains, the U.S. Fashion Industry Association said in a Dec. 1 blog post. “To our knowledge, the questionnaires, which relate to cotton, have not yet been distributed widely,” it said. Much of the information inquired about may not be available to importers so the questionnaires may be an effort from CBP “to get an idea of what they might expect from importers as a practical matter,” it said.
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The first questionnaire asks for cotton sourcing information, something that can be difficult to identify in some cases, USFIA said. “While it may be reasonable to expect that a fabric importer will be able to identify cotton sources, an importer of a blended fabric garment is not likely to be in that position,” it said. “Moreover, unless the factory buys cotton directly from the grower, it is logical to assume that the cotton came from multiple sources, both in terms of grower and region.” The questionnaire also seeks information about how forced labor issues are covered in purchase contracts and whether codes of contact cover forced labor, the association said.
The second questionnaire is similar to CBP questions around transshipment, USFIA said. “The important differences are references to certifications and audits relating to 'global standards,'” it said. “Another difference is including labor recruitment policies, and grievance resolution procedures as part of the factory profile.” CBP didn't comment.