UFLPA Will Require Importers To Submit China Postal Codes

Posted on Nov 11

Article by: Rick Walker, Vice President, TradeInsights, LCB, CCS

New ACE Deployment will Require Importers to Report the China Postal Code

In an effort to further strengthen the prohibition against the importation of goods made with forced labor, CBP has tentatively scheduled a new ACE deployment which will require importers or their brokers to report the China Postal Code associated with the company identified by the Manufacturer Identification Code (MID). The deployment was originally scheduled for November but has been delayed, and as of this writing the scheduled deployment date has not been determined. CBP issued a Uyghur Forced Labor Prevention Act Region Alert on November 2 explaining the new requirements.

According to the alert (found here), CBP will add new validations that will be performed when the Country of Origin is reported as China for entry and for the MID.

The new validations will be formed when:

  • The People’s Republic of China (CN) is selected as a manufacturer’s country of origin for entry
  • CN is selected as a manufacturer’s country of origin when a Manufacturer Identification Code (MID) is created, or
  • An existing MID with Country of Origin ‘CN’ is updated

The new validations will be:

  • Postal code will be a required field
  • Users will receive an error message if the postal code provided is not a valid Chinese postal code
  • Users will receive a warning message when a Uyghur region postal code has been provided

In a recent bi-weekly call with the trade community and after some pushback from the trade, CBP agreed to form a working group to further study the new requirement and get input on the proposed impacts of this new requirement. In the (announcement) of the formulation of the working group, Customs stated the following:

Specifically, CBP would like trade community feedback on the following:

  • Challenges with the proposed implementation of this enhancement and proposed alternative implementation approaches to mitigate these concerns
  • Time needed by the trade community for testing in the ACE Certification Environment
  • Identification of a date for deployment to ACE Production

We wanted to make everyone aware of this pending deployment. While the deployment date is still TBD while the working group studies the issues, importers may want to take this opportunity to confirm the postal codes for manufacturers in China.

We will continue to monitor this and provide updates as they become available.

Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions, and you can always follow us on our website www.valexander.com for updates on this and other topics.