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Keeping you in-the-know on environmental, social and governance developments

Between Ukraine and the SEC climate disclosure proposal, it has been easy to lose track of other major ESG matters. Here is a quick update on what is happening with the Uyghur Forced Labor Prevention Act, which I summarized at the end of last year here. As a reminder, the schedule for implementation as set forth in the law is below. It is worth noting that although regulations are contemplated by the law, no deadline for their promulgation is included in the legislation so the law and deadlines are self-implementing – including the importation ban on polysilicon, cotton and tomatoes originating from the Xinjiang Uyghur Autonomous Region (XUAR) that becomes effective in three months.

  • December 23, 2021 – H.R. 6256 signed into law.
  • January 26, 2022 (30 days after enactment) – Deadline for notice to be published in the Federal Register soliciting public comments on how best to ensure that covered items/materials are not imported into the U.S.
  • March 12, 2022 – End of 45 day public comment period.
  • March 23, 2022 – Deadline for Department of State to issue a diplomatic strategy to promote initiatives to enhance international awareness of and to address forced labor in the XUAR.
  • April 26, 2022 – (45 days after close of public comment period) – Deadline for holding a public hearing.
  • June 21, 2022 – (180 days after enactment):
    • Forced Labor Enforcement Task Force to submit to Congress a report on the strategy developed after public comment and public hearing. This strategy includes the guidance to importers on due diligence. 
    • Rebuttable presumption takes effect.

The public comment period closed March 10, in line with the legislative schedule (March 12 fell on a Saturday). Comments filed (totaling 180) can be viewed here.

Today is the deadline for Department of State to issue a diplomatic strategy to promote initiatives to enhance international awareness of and to address forced labor in the XUAR. We will see if that is issued by the legislative deadline.

The CBP Forced Labor Enforcement Task Force (FLETF) announced a public hearing will be held remotely via web conference on Friday, April 8, 2022, from 9:00 a.m. to 1:30 p.m. EDT. Members of the public interested in providing public testimony must register by Wednesday, March 30, 2022, 11:59 p.m. EDT. Register here. We will monitor the hearing and provides updates as appropriate.

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The Editor

Lawrence Heim has been practicing in the field of ESG management for more than 35 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting at the height of regulatory development, working across a range of disciplines. He was one of the firm’s leading environmental compliance and management… View Profile