Import from Thailand to USA: Forced Labor & UFLPA 2026
US Customs enforces a total ban on goods made wholly or partly with forced labor under 19 U.S.C. 1307. Thailand is not on the UFLPA entity list, but Thai shipments get caught two ways: upstream Xinjiang-origin inputs and Thailand's own migrant labor record in seafood, poultry, garments, and electronics assembly.
Where the risk actually sits
| Sector | Typical risk | Evidence CBP wants |
|---|---|---|
| Seafood / shrimp | Migrant crew, debt bondage | Vessel records, recruitment fee policy |
| Garments & textiles | Cotton origin, subcontracting | Yarn-forward traceability to farm |
| Solar & electronics | Polysilicon, metallurgical inputs | Bill of materials to raw input |
| Rubber gloves | Recruitment fees, passport retention | Worker payroll, no-fee recruitment audit |
| Poultry & food | Migrant labour brokers | Contracts and hour records |
What a detention looks like
CBP issues a detention notice and gives you 30 days to respond. You must prove by "clear and convincing evidence" that no part of the supply chain used forced labor. Practically that means a documented chain from raw material to finished good — invoices, production records, transport documents, worker payroll — not a supplier self-declaration.
Detained containers accrue demurrage the whole time. A failed response leads to exclusion or seizure.
Build the file before you ship
- Map tier 2 and tier 3. Know where your Thai factory buys yarn, resin, polysilicon or fishmeal.
- Contract it. Add a forced labor clause with audit rights and a zero-recruitment-fee policy to the supply agreement.
- Audit it. SMETA 4-pillar or amfori BSCI, plus unannounced worker interviews off-site.
- Keep records for 5 years. Purchase orders, production batch records, payroll summaries.
- Pre-assemble the traceability pack for high-risk SKUs so you can respond in days, not weeks.
Our factory verification process covers the on-site portion of this, and the supplier onboarding checklist covers the paperwork.
The commercial case
A single UFLPA detention on a $80,000 container costs roughly
2,000–20,000 in demurrage, storage and legal time even when released. One prevented detention pays for years of audits.FAQ
Is Thailand covered by the UFLPA?
Not directly — the UFLPA rebuttable presumption applies to goods from Xinjiang or listed entities. But Thai goods containing Xinjiang inputs are covered, and Thai goods are separately subject to the general Section 307 forced labor ban.
Which Thai products have Withhold Release Orders?
WROs have historically hit Thai seafood and fishing fleets. Check the active CBP WRO and Findings list before you contract in seafood or agriculture.
What documents does CBP accept as proof?
Transaction-level records tracing the finished good back to raw material origin: POs, invoices, packing lists, production and payroll records at each tier.
Will a social compliance audit alone clear a detention?
No. Audits support your case but CBP wants transactional traceability, not just a certificate.
How long does a UFLPA detention last?
30 days to submit, then CBP review. Straightforward releases take 4–8 weeks; contested cases run several months.