CBP's Forced Labor Tech Expo: A Turning Point for U.S. Importers
In March 2023, U.S. Customs and Border Protection held its first-ever Forced Labor Technical Expo in Washington DC, a two-day event at the Ronald Reagan Building that brought together technology providers, government agencies, NGOs, and members of the importing community. The event was designed to showcase the latest technologies in supply chain transparency and to reinforce CBP's enforcement posture under the Uyghur Forced Labor Prevention Act (UFLPA), which was signed into law on December 31, 2021. The UFLPA prohibits the import of goods mined, produced, or manufactured wholly or in part in China's Xinjiang Uyghur Autonomous Region, where the Chinese government has reportedly used forced labor of Uyghur Muslims and other ethnic and religious minorities. FRDM CEO and founder Justin Dillon had the privilege of presenting at the Expo, sharing how FRDM is helping leading global companies comply with the UFLPA. The event was live-streamed in addition to being held in person, making its message available to importers around the world. CBP's core directive to American importers was clear and direct: map your supply chain. The agency made plain that companies unable to demonstrate visibility into their supplier networks face real and escalating risk of shipment seizure and exclusion from U.S. commerce.
The vast majority of U.S. importers have no visibility beyond their direct, tier-one suppliers — a vulnerability CBP is actively targeting.
According to research cited by Dillon at the Expo, approximately 95% of companies have no visibility into their supply chains beyond their direct suppliers, placing an enormous share of U.S. imports at potential risk of CBP seizure. This statistic, drawn from Deloitte research, underscores why CBP's enforcement actions under the UFLPA are landing so broadly across industries — from apparel and agriculture to automotive, base metals, and consumer products. Since the UFLPA took effect in June 2022, thousands of shipments have been reviewed by CBP, with hundreds excluded from entry into the United States. Nearly $1.4 billion worth of goods with suspected ties to forced labor were seized at the U.S. border between June 2022 and July 2023 alone, with further increases expected. CBP also launched its UFLPA Enforcement Statistics Dashboard at the Expo, providing the trade community with real-time data on enforcement actions filterable by industry, exporting country, and shipment status — a tool that signals the agency's intent to increase both transparency and pressure on importers. FRDM maps and monitors supply chains with a specific focus on procurement, using invoice-level spend data to trace supplier networks up to eight tiers deep. This approach allows FRDM to help customers identify which upstream commercial relationships may connect them to forced labor risk, enabling them to take corrective action before a shipment is detained at the border.
FRDM was purpose-built to give companies the deep supply chain visibility that regulators now demand.
FRDM was among 18 technology vendors showcased at the Expo, categorized as a supply chain mapping provider — one of the most critical capabilities for UFLPA compliance. Unlike solutions that only screen direct suppliers against watchlists, FRDM's platform maps sub-tier supplier relationships, which is increasingly a required component of UFLPA due diligence for high-risk products and components. CBP has made clear that it wants empirical evidence of supply chain engagement, not simply a code of conduct or a checklist. The FRDM platform uses simple invoice-level spend data as its starting point, requiring no complex ERP integration to begin generating visibility. From there, it risk-ranks suppliers, identifies upstream commercial connections, and predicts potential exposure to forced labor. The company is also ISO 27001 certified and offers dynamic reporting tools to help companies communicate their compliance efforts to boards, executive management, procurement teams, suppliers, and trade associations — all of which CBP may ask to see in the event of a detention.
Supply chain transparency is no longer a values statement — it is a business and legal necessity with direct financial consequences.
Justin Dillon has argued for years that supply chain transparency is not only the right thing to do ethically, but that it makes fundamental business sense. The business case has now been dramatically sharpened by regulatory enforcement. Forced labor risk is not confined to China — the U.S. Department of Labor has documented forced and child labor concerns across dozens of countries, and CBP has stated that forced labor enforcement will remain a top trade priority going forward. Companies that remain complacent because they do not directly import from known risk regions may still face liability through their sub-tier suppliers. At the Expo, DHS Under Secretary for Policy Rob Silvers described the UFLPA as having caused a fundamental shift in the forced labor enforcement regime. The law's rebuttable presumption — that any goods from Xinjiang are made with forced labor unless proven otherwise — places the evidentiary burden squarely on the importer. For companies unprepared to meet that burden, the consequences are tangible: shipment detentions, exclusions from U.S. commerce, reputational damage, and significant financial loss. FRDM's participation at the CBP Tech Expo reflects its position at the intersection of this regulatory moment and the technology needed to respond to it.
*not sales material disguised as 'resources.'