CTPAT and its new Forced Labor requirements
The Customs Trade Partnership Against Terrorism (CTPAT) is a supply chain security program led by U.S. Customs and Border Protection (CBP). The program was launched in 2001 as a result of the 9/11 attacks on the United States and was created to increase the involvement of the business community in the fight against terrorism. CTPAT has been expanded to include an anti-forced labor provision. This closely aligns the program with U.S. Customs enforcement of Section 307 (the so-called forced labor ban).
What has changed?
The new forced labor provision of CTPAT requires that companies ensure that “goods imported into the United States were not mined, produced or manufactured, wholly or in part, with prohibited forms of labor, for example — forced, imprisoned, indentured, or indentured child labor.” In addition to the supplier questionnaire used to manage CTPAT, the forced labor provision means that companies are required to provide supply chain mapping data upon request.
What is supply chain mapping?
Supply chain mapping is the process of documenting the life of products from raw materials to finished goods. Most companies only maintain a database of direct suppliers, so there is little visibility to raw material origins. Supply chain mapping software enables visibility to raw materials through a LinkedIn-style approach where companies invite their suppliers, who invite their suppliers, and so on until the raw materials suppliers are identified.
What should companies do to meet the new Forced Labor requirements of CTPAT?
Companies should implement supply chain mapping software to meet the new anti-forced labor provision of CTPAT. The benefits are:
Supplier discovery: For every direct supplier, companies should expect to discover 5-10 indirect suppliers. Supply chain mapping software automates the process of identifying these vendors.
Forced labor due diligence: In high-risk regions, sub-suppliers need to provide evidence of compliance which may include documented policies and procedures as well as documents to validate commercial practices.
Consolidation: Both traditional CTPAT questionnaires and the new forced labor due diligence data can be collected from the same suppliers using the same software, minimizing effort on the part of suppliers, while consolidating findings in a single source of truth for compliance reporting.
Want to find out more about CTPAT and forced labor regulation? Contact us at info@sourcemap.com