Section 307 Compliance: What Importers Need to Know

In June 2026, U.S. Customs and Border Protection (CBP) published its Forced Labor Enforcement Operational Guidance for Importers. It sets out the evidence CBP expects, the standard audits must meet, and what happens when records have gaps. The guidance arrives as enforcement expands, with CBP stopping more than 44,000 shipments worth over $4 billion under the Uyghur Forced Labor Prevention Act (UFLPA) alone since 2022.

Section 307 of the Tariff Act of 1930 bans goods made with forced labor from entering the United States, and CBP can hold a shipment on suspicion alone. Section 307 compliance defines the process and records that lets an importer show CBP its goods are admissible.

This article presents what importers are responsible for, how to assess and document forced labor risk, how to build a compliance program, and how to respond when CBP acts.

What Is Section 307 Compliance?

Section 307 compliance is the system of controls and records an importer uses to show CBP its goods were not made with forced labor. here’s no certificate to earn or form to file that makes a company compliant. Instead, CBP looks at the evidence behind each shipment and decides whether it holds up.

The ban itself, codified at 19 U.S.C. 1307, bars goods mined, produced, or manufactured wholly or in part with forced labor, convict labor, or indentured labor in any foreign country. Our guides to the Section 307 forced labor import prohibition and the history of Section 307 of the Tariff Act of 1930 cover the ban in detail.

Section 307 applies shipment by shipment, unlike the 2026 Section 301 forced labor action, which adds 10% or 12.5% duties on imports from 60 economies regardless of an importer’s controls (91 FR 47318).

Who Needs to Consider Section 307 Compliance?

Every importer of record needs to be aware of Section 307 and how to stay compliant. Contracts with suppliers, customs brokers, or freight forwarders do not shift that legal duty.

The ban covers any country and product. CBP has put a large focus on China’s Xinjiang Uyghur Autonomous Region (XUAR), but recent orders have also targeted producers in Jordan, Serbia, Taiwan, and Indonesia. Formal controls matter most for importers that:

• Source in one of the 12 high-priority sectors for UFLPA enforcement.
• Buy commodity inputs, such as cotton or aluminum, that are often mixed before reaching a manufacturer.
• Run multi-tier supply chains they cannot yet trace to the raw material.
• Import goods with any connection to the XUAR or to an entity on the UFLPA Entity List.

What Are Importers Responsible For?

Importers are responsible for exercising reasonable care, a duty that comes from customs entry law, not Section 307. Under 19 U.S.C. 1484, the importer of record must use reasonable care when filing entry documents. That means taking the steps a careful, informed importer would take to make sure its declarations are accurate. CBP’s guidance says the duty covers compliance with forced labor laws, and its reasonable care informed compliance publication explains the standard further.

CBP doesn’t require any specific tool or program, but its guidance makes clear that meeting the standard comes down to three things:

• Knowing where and how goods are produced. Because the ban covers goods made “wholly or in part” with forced labor, the duty reaches every input. That extends deep in the supply chain, well beyond Tier-1 suppliers.
• Keeping evidence for every company in the chain. When CBP reviews a shipment, it bases its decision on the paperwork the importer can produce. Records need to cover every supplier involved, not just the major ones. In UFLPA cases, CBP’s guidance warns that missing records for even one supplier can sink the entire case.
• Running due diligence continuously. CBP expects a documented process that screens, monitors, and responds to risk over time.

Section 307 and UFLPA: What’s the Difference?

The UFLPA isn’t a separate ban, but it changes how the Section 307 ban works for certain goods. If a product was made, even in part, in the XUAR or by a company on the UFLPA Entity List, CBP assumes it was made with forced labor. It’s then up to the importer to prove otherwise, rather than up to CBP to build a case.

	Section 307 (WRO case)	UFLPA
Scope	Any country and any product	Goods linked to the XUAR or to listed entities
Trigger	CBP investigates and issues a withhold release order (WRO) on reasonable suspicion	Presumption applies automatically to goods in scope
Importer must show	The goods are admissible	The presumption does not apply, or clear and convincing evidence that rebuts it
Review type	Admissibility review	Applicability review (no link to the XUAR or a listed entity) or exception request (rebutting the presumption)
Time to respond	Three months from importation	Usually 30 days from the detention notice

As of Oct. 21, 2026, CBP had stopped 44,651 shipments worth $4.14 billion under the UFLPA since June 2022. It denied entry to 27,098 and released 15,547, with the rest still under review, according to its UFLPA enforcement statistics dashboard.

The UFLPA Entity List also changes quickly. The Department of Homeland Security (DHS) announced its largest single expansion, 43 entities, on July 31, 2026, and the additions took effect on publication Aug. 3 (91 FR 48913), bringing the list to 187.

The Countering America’s Adversaries Through Sanctions Act (CAATSA) creates a similar presumption for goods made with North Korean labor.

How to Assess Forced Labor Risk Across the Supply Chain

Assessing forced labor risk answers two questions: where forced labor could enter the supply chain, and whether it exists at a given supplier. CBP breaks the work into three steps.

Map Suppliers and Production Locations

Supply chain mapping should include every component of a product, from the finished good to the raw material. CBP frames what it expects as four questions:

• Who was involved at each stage of production, and in what role?
• Where did production take place?
• How were the goods sourced and processed?
• What components were the goods made from?

Timing is the reason to map early. Importers often have as little as 30 days to answer a UFLPA detention, and suppliers several tiers back rarely turn records around that fast. Mapping before a shipment is stopped gives importers a head start on the evidence CBP will ask for.

Identify High-Risk Products, Suppliers, and Regions

CBP points importers to three screening sources:

• CBP’s Withhold Release Orders and Findings dashboard shows which producers and goods face enforcement. As of Sept. 29, 2026, CBP was enforcing 60 WROs and eight Findings.
• The UFLPA Entity List names the entities whose goods are presumed prohibited.
• The Department of Labor’s List of Goods Produced by Child Labor or Forced Labor covered 204 goods from 82 countries at its last update in September 2024. At least 75 of those goods, from 44 countries and areas, involve forced labor.

The UFLPA Strategy names 12 high-priority sectors, each with recommended documentation in CBP’s guidance: aluminum, apparel, caustic soda, copper, cotton and cotton products, lithium, polyvinyl chloride, red dates, seafood, silica-based products (including polysilicon), steel, and tomatoes and downstream products.

Assess Forced Labor Indicators

CBP’s Forced Labor Division uses the 11 ILO Indicators of Forced Labour to test the legal definition’s three elements: work, a penalty or threat that compels it, and lack of free consent:

• Abuse of vulnerability
• Deception
• Restriction of movement
• Isolation
• Physical and sexual violence
• Intimidation and threats
• Retention of identity documents
• Withholding of wages
• Debt bondage
• Abusive working and living conditions
• Excessive overtime

CBP generally doesn’t accept any audit that skips the ILO indicators as enough to reduce forced labor risk. It suggests unannounced audits by independent auditors.

Several indicators, such as debt bondage and withheld wages or documents, rarely surface in questionnaires or announced visits. Importers need worker-level channels, such as anonymous surveys and grievance reporting, to find them.

How to Build a Section 307 Compliance Program

A Section 307 compliance program helps turn a risk assessment into a repeatable, documented system. CBP’s guidance lists eight due diligence elements to include:

1. Engage suppliers and stakeholders on forced labor risk.
2. Map the supply chain and assess risk, as described above.
3. Adopt a supplier code of conduct that prohibits forced labor and flows down past tier one, backed by a contractual right to subcontractor records. CBP’s own test: if a company in the chain cannot or will not provide requested documents, consider a new supplier.
4. Train employees and agents who select suppliers, since screening at selection is the cheapest point to avoid exposure.
5. Monitor on two fronts: each supplier’s performance against the code and the ILO indicators, and outside changes such as Entity List additions and new WROs. 
6. Remediate or terminate. When forced labor is found, CBP accepts two outcomes: the supplier fixes it, or the importer ends the relationship. Indefinite observation is not an option. Record each decision, its reasoning, and the timeline.
7. Verify independently that the system is in place and working.
8. Report publicly on the system.

No single team can run this program alone. Trade compliance usually handles CBP, procurement chooses suppliers and sets contract terms, and sustainability teams hold the supplier assessments CBP will want to see.

EcoVadis supports several of the eight elements at scale. EcoVadis IQ Plus maps forced labor and human rights risk by country and industry, showing where to map and audit first. EcoVadis Ratings and Vitals assess suppliers’ labor and human rights practices and track corrective actions, creating a comparable record for monitoring and remediation. Worker Voice gathers input directly from workers on the indicators employer records miss. No EcoVadis tool traces raw materials such as cotton to source, so commodity-heavy importers need dedicated traceability too, and no rating alone establishes Section 307 compliance.

What Documentation Should Importers Maintain?

Importers should maintain four types of records for every company in the supply chain:

• Supplier and production records: invoices, purchase orders, contracts, packing lists, bills of lading, proofs of payment, production records, and payroll. Certificates of origin and manufacturers’ affidavits should name the entity and the location where each material was mined, processed, or manufactured.
• Traceability records: evidence of the physical path of goods and inputs, showing nothing from higher-risk sources was mixed in. Where origin rests on a supplier’s word, CBP encourages testing, such as isotopic testing of a material’s chemical signature, as support for records rather than a substitute.
• Due diligence records: proof that each of the eight program elements operates, including risk assessments, audit reports against the ILO indicators, training records, and remediation decisions.
• Admissibility evidence for WRO cases: a certificate of origin in the form 19 CFR 12.43(a) prescribes, since a standard commercial certificate does not qualify. Section 12.43(b) also requires a detailed statement from the importer, not the seller, showing every reasonable effort to trace the goods, their components, and the labor used.

Organizing records by component and production stage makes a detention response far faster to assemble.

Common Section 307 Compliance Challenges

Most compliance gaps come from three problems:

• Limited visibility past tier one. Few companies can see beyond their direct suppliers, yet CBP’s standard reaches the raw material. Contracts that flow documentation duties down the chain, plus supplier flowcharts showing who performs each production step, close much of the gap.
• Suppliers that will not share records. A supplier that withholds documents is a compliance risk, regardless if it appears to be performing well. Making document sharing a condition of selection gives importers more leverage.
• Commingled raw materials. Cotton, polysilicon, aluminum, and copper are often mixed before reaching a manufacturer, so paperwork rarely proves origin alone. Segregation records, origin testing, and CBP’s sector documentation guidance fill the gap.

How to Respond to CBP Enforcement

What happens after CBP stops a shipment depends on which law it acts under, because each one comes with its own deadline and bar for evidence. Those deadlines don’t pause while an importer waits on suppliers for records, so it pays to know the process ahead of time.

CBP starts with a detention notice. Under 19 U.S.C. 1499 and 19 CFR 151.16, the notice states why CBP detained the goods, how long the detention should last, and what the importer must submit. Costs start immediately: the importer pays storage for the whole review, whatever the outcome, and CBP may require a single transaction bond of three times the goods’ value.

Next steps depend on the authority:

• WRO: CBP detains the goods on reasonable suspicion. The importer has three months from importation to export them, destroy them, or request an admissibility review.
• Finding: CBP seizes the goods on probable cause, and they cannot be exported. The importer generally has 30 days to petition. Our guide to Section 307 Findings covers the process.
• UFLPA: The importer files an applicability review or exception request, usually within 30 days of the detention notice.
• CAATSA: The importer has 180 days to export, destroy, or protest an exclusion.

Importers file every response through CBP’s Forced Labor Portal. CBP expects numbered exhibits grouped by component or production stage with an index, confidential information in double brackets, text-searchable scans, and English translations.

Members of the Customs Trade Partnership Against Terrorism (CTPAT) Trade Compliance program receive:

• Priority review of admissibility packages.
• The option to hold affected shipments at their own facility.
• Advance notice, where possible, of a potential hold, detention, exclusion, or seizure.
• 48 hours’ notice of a new WRO or Finding.

If an importer finds forced labor in goods already imported, 19 U.S.C. 1592 lets it file a prior disclosure before CBP discovers the violation, which can substantially reduce or cancel a penalty.

Section 307 Compliance Checklist

Completing the checklist creates no safe harbor, since CBP judges each shipment on its facts.

1. Map the supply chain to raw materials, recording who, where, how, and what at each stage.
2. Screen suppliers against the WRO dashboard, UFLPA Entity List, and Department of Labor list on a set cycle.
3. Maintain a supplier code of conduct that flows down past tier one, with a right to records.
4. Commission unannounced, independent audits against all 11 ILO indicators.
5. Collect worker-level information for indicators employer records do not show.
6. Hold transaction, production, payroll, and transport records for every company, organized by stage.
7. Document remediation and termination decisions, with reasoning and dates.
8. Assemble a response package before any detention, formatted to CBP’s conventions.

FAQs

What are the Section 307 compliance requirements?
Section 307 sets no prescribed steps to compliance. The working duty is reasonable care under 19 U.S.C. 1484, which CBP reads as requiring importers to understand their supply chains and hold evidence their goods are free of forced labor.

What documentation should importers keep?
Importers should keep detailed supplier, production, and traceability records for every company from raw material to finished good. They should also maintain due diligence record, including audit reports and remediation decisions.

Does Section 307 require supply chain due diligence?
Section 307 does not directly require supply chain due diligence. But meeting reasonable care at entry, and the burden of proof after a detention, requires due diligence done in advance.

How does Section 307 compliance differ from UFLPA compliance?
The UFLPA enforces the same ban but presumes goods linked to the XUAR or listed entities are prohibited. Rebutting it takes clear and convincing evidence, usually within a shorter window than a WRO case.

Sources last verified: Checked against CBP, the Department of Homeland Security, the Department of Labor, the ILO, and the Federal Register on Oct. 21, 2026.