Dear Colleagues,
Last week, U.S. Customs and Border Protection (CBP) announced the official launch of the Forced Labor Portal, a new centralized online system that is now mandatory for submitting certain forced-labor–related review requests.
Effective as of January 21, 2026, importers and their representatives must use this Portal to submit the following requests to CBP:
- Withhold Release Order (WRO) admissibility reviews
- Uyghur Forced Labor Prevention Act (UFLPA) applicability reviews
- UFLPA exception requests
- CAATSA (North Korea–related) exception requests
CBP has made clear that email or paper submissions will no longer be accepted for these matters. Requests submitted outside the Portal may result in delays or outright rejection.
The Forced Labor Portal is intended to centralize review intake and assign matters to the appropriate CBP office (Forced Labor Division, Port of Entry, or Center of Excellence and Expertise).
All users must authenticate through LOGIN.gov, and both primary and secondary points of contact must have active LOGIN.gov accounts.
Why this matters:
Detentions and exclusions tied to forced labor enforcement already carry tight deadlines and heavy evidentiary burdens. The Portal adds a new procedural layer that, if not handled correctly, can itself become a point of failure. Incomplete submissions, improper document formatting, or delays in Portal registration can jeopardize admissibility reviews and exception requests.
Recommended next steps for importers:
- Confirm that your internal teams and outside brokers understand the new Portal requirement
- Ensure relevant personnel have active LOGIN.gov credentials
- Review your forced labor response playbooks, including document readiness and translation protocols
- Identify products, suppliers, or regions that may trigger UFLPA, WRO, or CAATSA scrutiny
Poblete Tamargo LLP regularly advises clients on compliance with federal trade laws and regulations and can assist with reviewing and preparing submissions through the Forced Labor Portal. If you have questions about how this change affects your operations—or if you are facing an active detention or exclusion—we are available to assist.
This post is for general informational purposes and does not constitute legal advice. Reading it does not create an attorney-client relationship. Each case turns on its facts. Poblete Tamargo is a boutique national security law and public policy practice advising clients on complex matters, including complex consular matters, wrongful detention by foreign governments, economic sanctions, export controls, and congressional oversight. We also counsel employers and travelers on compliant travel planning, documentation, and government engagement strategies. To discuss a specific situation, contact our team.