CBP Launches Mandatory Forced Labor Portal for Importers

Crowell & Moring Trade Blog

Published January 21st, 2026

Detected March 1st, 2026

Summary

U.S. Customs and Border Protection (CBP) has launched a new, mandatory online Forced Labor Portal for importers to submit requests challenging shipment detentions or exclusions related to forced labor enforcement. This centralized platform replaces previous submission methods and is effective immediately.

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What changed

U.S. Customs and Border Protection (CBP) announced the immediate mandatory use of its new Forced Labor Portal for all importers seeking to challenge or obtain exceptions for shipments detained or excluded under U.S. forced labor laws. This includes requests related to Withhold Release Orders (WROs), forced labor findings, the Uyghur Forced Labor Prevention Act (UFLPA), and other sanctions. The portal aims to streamline the submission process, consolidate documentation, and formalize CBP's administrative record for these enforcement actions.

Importers must now use this portal for all admissibility review and exception requests. Companies need to ensure their internal procedures and document retention practices align with the portal's requirements, paying close attention to compressed timelines, especially for UFLPA detentions. Accurate, timely, and complete submissions are critical, as they will form the basis of CBP's admissibility determinations and may be relevant for subsequent administrative protests or judicial review.

What to do next

Update internal procedures to mandate the use of the CBP Forced Labor Portal for all WRO, UFLPA, and other forced labor-related admissibility review and exception requests.
Ensure all relevant documentation is accurately and completely submitted through the portal within statutory and administrative timelines.
Review and align document retention practices with the requirements of the new portal submission process.

Source document (simplified)

On January 21, 2026, U.S. Customs and Border Protection (“CBP”) announced that its Forced Labor Portal is now live. This new online portal provides a single, centralized platform for importers to submit requests for review when their shipments are detained or excluded due to forced labor enforcement actions. By consolidating what was previously a patchwork of email and paper submission processes, the portal is intended to streamline communications and ensure that all forced labor-related documentation reaches the appropriate CBP officials for timely review.

Effective immediately, use of the Forced Labor Portal is mandatory for importers seeking to challenge or obtain exceptions for shipments held under U.S. forced labor laws. This includes filing admissibility review requests for goods detained under Withhold Release Orders (“WROs”) or forced labor findings, as well as review and exception requests related to the Uyghur Forced Labor Prevention Act (“UFLPA”) and other forced labor sanctions.

From a compliance and litigation standpoint, the Forced Labor Portal helps formalize CBP’s administrative record for forced labor enforcement actions. Information submitted through the portal is expected to form the basis of CBP’s admissibility determinations and may be relevant in subsequent administrative protests or judicial review before the U.S. Court of International Trade. As a result, the accuracy, timing, and completeness of portal submissions carry heightened legal significance.

Importers should be mindful of compressed administrative and statutory timelines, particularly for UFLPA detentions, which generally provide a shorter window to submit rebuttal evidence than traditional WRO cases. Companies should ensure that internal procedures and document retention practices are aligned with the portal’s submission requirements.

CBP has published a Quick Reference Guide and an instructional video on its website to assist users with the transition to the portal.

Crowell & Moring LLP continues to monitor developments in forced labor prevention enforcement, including CBP’s implementation of the Forced Labor Portal, and its impact on industry.

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Crowell & Moring is a full-service international law firm that represents major businesses – both public and private – in complex high-stakes litigation, enforcement, regulatory and administrative, transactional matters, and government and internal investigations. Our Trade Law Blog features legal insight and thought-leadership affecting the industries and business reliant and affected by international trade.