On October 28, 2022 we sent clients a notice that CBP will begin requiring the China postal code when creating and updating China Manufacturer Identification Codes (MIDs) and when filing CBPF 3461 Cargo Release entries on China-origin merchandise, as part of its enforcement under the Uyghur Forced Labor Prevention Act (UFLPA). UFLPA bans importation of goods made in whole or in part in the Xinjiang Uyghur Autonomous Region or by entities on the UFLPA Entity List. We provided an update via “Briefings” on November 15, 2022 that the deployment date for this program had been delayed.
A new schedule has been released by CBP, indicating a target deployment date (subject to change) of March 18, 2023. The schedule provides that ACE (Automated Commercial Environment) will issue a warning message when a Uyghur region postal code is provided and an error message when invalid Chinese postal codes are provided. China postal codes will be needed for updated and new China MIDs and “MF” Manufacturer/Supplier parties reported on Customs CBPF 3461 Cargo Release entries of China-origin merchandise.
We have identified an unofficial list of Xinjiang postal codes. We recommend that clients immediately begin reviewing and confirming these postal codes against supplier addresses.
The CBP schedule also announced the “UFLPA Detention Process Related to Forced Labor” that will automate Admissibility Reviews and Exception Requests and the preparation and issuance of Detention Notices and Custody Receipts. It has a target deployment date of May 2023.