CBP’s new ‘forced labor’ rules burden every link in the chain

ID 18606536 © Francesca Braghetta | Dreamstime.com By Adam Clermont 01/07/2026 Key takeaway: The agency’s consolidated guidance makes explicit what was only implied: if an importer can’t document every supplier in a production chain, every single one, goods are denied entry. For forwarders and BCOs, this rewrites the economics of sub-tier visibility. There is a passage buried in U.S. Customs and Border Protection’s new, roughly 80-page ’Forced Labor Enforcement Operational Guidance’ for Importers that should make every logistics executive reading this set down their coffee. It is not a new ...