미국의 위구르 강제노동방지법 시행 현황과 시사점

다국어 초록 (Multilingual Abstract)

Even before the introduction of the Uyghur Forced Labor Prevention Act (UFLPA), the U.S. has imposed sanctions on products related to human rights violations in accordance with Section 307 of the U.S. Tariff Act of 1930 and Global Magnitsky Human Rights Accountability Act. However, with the implementation of the UFLPA, strengthened measures have been introduced for products related to human rights violations, as imports to the U.S. of goods made in Xinjiang Uyghur Autonomous Region and goods assembled or manufactured in countries other than China using raw materials from the Xinjiang Region have been prohibited.
During the first year of the implementation of the UFLPA, more than $500 million worth of shipments had been denied and more shipments from Malaysia and Vietnam than from China had been held for customs clearance. In this regard, companies need to set up a supply chain due diligence system that is capable of examining raw materials and intermediate goods from countries other than China, along with a supply chain tracking system and a system that enables companies to receive relevant data from suppliers in advance, in order to minimize potential risks.
As concerns have been raised regarding some companies’ attempts to circumvent UFLPA investigations, the U.S. may strengthen its investigation procedures and further delay the customs procedures in the future, with an additional introduction of legal grounds to facilitate investigations related to the circumvention of UFLPA.