Expeditors International of Washington, Inc. (EXPD) Earnings Call Transcript & Summary

Hello, everyone, and welcome to Expeditors U.S. Enforcement of Forced Labor webinar. My name is Nicole, and I'm going to be hosting the webinar today. And we will be going about 90 minutes in total, about 60 to 70 minutes of presentation material and then a Q&A session at the end. [Operator Instructions] You will be receiving a copy of the presentation that was shared today in the webinar upon a short feedback survey. I will be sending that out after the webinar. Once that is completed and you hit submit, you'll be directed to another landing page where you can download a PDF copy of the presentation material. Now I'm going to go ahead and introduce our webinar speakers. We have with us Therese Randazzo, Special Advisor from U.S. Customs and Border Protection. We also have Brenda Smith joining us from Expeditors, our Global Director of Government Outreach; Madeleine Veigel, Director of Customs for the Americas; and Ted Henderson, Senior Advisor for Customs for the Americas. I'll hand it over to Ted.

Thank you, kindly, Nicole, and thank you, kindly, to everyone for joining this webinar today. We appreciate you joining the discussion. It's really one of the most important topics right now in the U.S. import environment. And we definitely want to share the most recent information about what's going on. We also know we're competing with other interesting news going on in the United States today. So I appreciate you hanging with us for the next 1.5 hours, and I'm sure you can watch what's going on, on your phone as well. I do want to say not only are we appreciative of you all joining the call, but we're definitely appreciative of Therese Randazzo from U.S. Customs and Border Protection. Being a part of this discussion, I've had the pleasure of knowing Therese for a while. I won't say how long, but we both worked together back at the legacy U.S. Customs service a while back, and Therese continued her career when U.S. Customs became U.S. Customs and Border Protection. Has worked in a number of areas. She's worked in the ports. She's worked in headquarters. She's worked internationally. And for the last several years, she specifically has been involved with the forced labor enforcement efforts by U.S. Customs and Border Protection. She's been part of the Trade Remedy Law Enforcement Directive and really been involved in the actions of CBP from the outset of the Uyghur Forced Labor Prevention Act and even earlier activities on that. So we are very fortunate to have Therese involved in this discussion today and hopefully, you'll get a lot out of that. As folks continue to come in to the webinar, I'm just going to take my time to go through the agenda and give you an idea of what our intent here today. Really, we're going to start with a high-level overview, just to give you some quick background on forced labor in general, statistics, things along that line. Will get into the legacy Forced Labor Reinforcement actions, pre-UFLPA that CBP has been engaged in the Section 307 enforcement and some related statutes. Then we're going to do a quick overview of the Uyghur Forced Labor Prevention Act and talk about that part. Give you some views as to a process flow that we've put together on decision points and things that you need to be thinking about, should you have goods detained. And then we're really getting to the heart of the matter with Therese, spending a lot of time concentrating on the most recent guidance that CBP has been offering, related to how to prepare for detention, what do you do when you're an attention, what should you be thinking about well in advance right now with respect to your supply chain, so -- and then at that point, we'll start winding down with a view of, again, things for -- that you should be thinking about. We have a very extensive resource page at the end of this, lots of links to a variety of areas that we believe will be useful to you. And then we'll go into Q&A part and hopefully grab all your questions as they go. Again, as Nicole stated at the opening, if you weren't able to join right away. Do understand that we will provide a copy of this presentation, all the slides, you will see those. So you don't need to frantically take notes or anything else, screen grab as it goes. You will get this material at the conclusion of the webinar. We'll also -- again, you'll get those resource links as it goes. So really, this -- again, our goal is to provide information for you as the importers so that you're able to make your best effort to be compliant with U.S. law in this critical area, and really minimize the possibility of the presence of forced labor in our collective supply chains. None of us want that. None of us have any interest in that. And so this is really part of our collective effort to do the right thing. Final thing I will say is that during these webinars for folks who have been involved in these before, we do periodically offer our own opinion from an expeditors perspective, but we will try to make that clear if we are offering opinions. But generally, you will see fact from us, and you will definitely see fact from CBP. So we'll get going with that. And let's kick things off with my colleague, Brenda Smith, chatting about really the overview and get us rolling here. Brenda?

Thanks very much, Ted. And what I wanted to do was to start out with maybe an indication of why this is so important. What we have seen in the last 8 to 10 years is very significant government focus on addressing human rights issues, but particularly the issues around forced labor. With the implementation of the U.K. Modern Slavery Act, the Australia Modern Slavery Act, and certainly, the higher profile of authorities here in the United States around forced labor. And the reason I think that governments are taking this issue so seriously is that there are over 27 million people who are believed to be in situations of forced labor around the globe. It's a huge number, and these estimates come from the International Labor Organization whose mission it is to ensure that people can work in fair and free environments. They have done a tremendous amount of work on trying to understand situations of forced labor and have issued, which you can find on their website, a pretty good list of what the indicators are of forced labor in manufacturing facilities and in agricultural facilities or in extractive industries. And those issues or those indicators include things like physical and sexual violence against workers. The restricted movement, in other words, passports are often taken or employees are not allowed outside of the manufacturing compound. Wages can be held. There may be excessive overtime or debt bondage, where employees have borrowed money from the company, sometimes unknowingly and just are never in a situation where they can pay back that money and thereby leave that place of employment. There may be intimidation and threats or the retention of identity documents. The reason that these indicators are important is because they are used by Customs and Border Protection to assess allegations of forced labor as they go about determining which shipments won't be allowed into the United States. Next slide, please. And so the authority that U.S. Customs and Border Protection used as to exclude goods made wholly or in part with forced labor actually comes from the Tariff Act of 1930. So it is fairly, I'll say, traditional authorities, which weren't much used in the 20 to 40 years before 2016. When with the passage of the Trade Facilitation and Trade Enforcement Act, not only was a loophole in the forced labor provision closed. But there was also a significant profile, increased profile among non-governmental organizations, the U.S. Congress and the Administration. The enforcement of 1307 goes right alongside a number of other human rights provisions that can be found in USMCA, the TVPRA, the Trafficking Victims Protection Act, the Uyghur Human Rights Policy Act, the [indiscernible] Human Rights Act and the Countering America's Adversaries Through Sanctions Act, all of which take a different but complementary approach to human rights issues. Next slide. And I'll turn it over to my colleague, Madeleine.

Thank you so much, Brenda. So how does CBP enforce forced labor? And we're going to talk about a couple of different ways. The first 2 here are through the Withhold Release Orders or through a finding. And Withhold Release Orders or WROs are probably the most common ways in terms of how CBP forces forced labor. So literally, Withhold Release Order are instructions that are sent by the Commissioner of Customs to the CBP Port Director. And basically, those instructions say, "Hey, this particular commodity from this entity cannot be entered into commerce into the United States." That particular commodity from that particular entity is withheld from release. So when you receive a withhold release order, you'd have to -- there's -- basically, you have a couple of choices. One is you can provide documentation to customs. Basically proving the fact that the goods that you're trying to import were not manufactured by forced labor. Or If you don't have all that documentation that you can supply at that time, you can reexport or basically destroy the goods. So there's a couple of different options you have with the withhold release order. Withhold release orders, when they are issued, they're also published on CBP's website. So if you go -- and we'll be giving you all the links, but you will see all the withhold release orders that are currently active and that have been issued. Withhold Release Orders are usually issued again against the company. Sometimes, it can also be a fishing vessel, but mostly they're against companies in particular countries or a particular commodity. So again, and with the withhold release order, I should say, too, that customs has reasonable evidence, right, when they issue withhold release order, they've got reasonable evidence that within that particular company, they're using forced labor to manufacture that product. Now on the flip side or on the second part of the screen here, you see forced labor findings and a finding is a little bit different of finding CBP actually has conclusive evidence that forced labor was used to make that particular commodity by that particular entity. So it's a stronger, higher level of evidence that they have when they issue a finding. Findings basically state that the port directors can seize the -- importation can seize the merchandise immediately and actually initiate forfeiture actions. The findings are also posted on CBP's website as well as a Federal Register notice is issued. And the one big difference with the finding is though you can also put together information to fight the finding, basically to put a packet of an appeal together to say, "Hey, I know that my goods that are coming in from this particular country, were actually not manufactured with forced labor." You can put in an appeal together. However, you are not able -- if it's denied or if you decide not to do that, you are not able to reexport the goods under a finding. You can only destroy the goods. So that's another big difference with the finding. Findings, again, there are far fewer findings than there are withhold release orders. Withhold release orders, there are far many of those than actual findings. And we can actually -- to give you kind of a flavor of that, we can go to the next slide, please. This chart is directly from CBP's website. So you can find it there, it was last updated as you see at the bottom of the chart on the 15th of March. And the gold circles are withhold release -- -- active withhold release orders and the red circles are findings. So you see that they are far more gold circles than there are red circles. And again, with the withhold release order, custom has reasonable evidence that forced labor was used to manufacture the product, whereas with the finding they have, they have conclusive evidence, that forced labor was used to manufacture the product. You will see as well that the majority of the withhold release orders and findings are out of China. So if you look at the map and you see kind of on the right-hand upper side, 35 active withhold release orders and 5 active findings. And in total, across the globe, there's currently 53 active withhold release orders and 8 active findings. And we do anticipate that we'll continue to see this through this year as Customs has also received quite a bit of funding to enhance and increase their personnel dedicated to fighting forced labor. So I will now pass the baton actually to my colleague, Ted, to talk about the UFLPA. Ted?

So thanks, Madeleine. As Madeleine was talking about, so these are the tools that CBP has been using under the law that Brenda was talking about, under the Tariff Act of 1930 and Section 1307. These were the traditional tools that CBP was using to deal with forced labor. As Madeleine pointed out, you saw that China was clearly a main focus of forced labor enforcement when you're looking at the WROs. And as it was going over the several years ago, CBP and other U.S. government agents really started to focus in on a particular area of China, and that's the Xinjiang Uyghur Autonomous Region. And that was really based on allegations on how China is treating the largely Muslim population in that region. Several NGOs, CSOs, academics, some news agencies started producing a lot of information about alleged forced labor actions by the Chinese companies party in the Xinjiang region. So from that, we started to see more activity from the government. And based on this growing body of information allegations, the U.S. Department of State Treasury, Commerce and Homeland Security issued a Xinjiang Supply Chain business advisory. They updated it in July 2021. At the same time, U.S. Congress was really starting to look at this and decided that additional legislation needed to go into effect to specifically address this forced labor concern in this particular region of China. So the Uyghur Forced Labor Prevention Act was passed by both houses, both house representatives and Senate. It ultimately went forward to President Biden and was signed in December of 2021. There was a 180-day runway for it to become effective for Department of Homeland Security, CBP, and a number of other federal agencies to implement it and get it into effect and it -- again, ultimately, it became effective on the 21st of June in 2022. So this act is different than the legacy, if you will, the 1307-type forced labor enforcement. This act put some very specific language in related to products that might be associated with the Xinjiang Uyghur Autonomous Region. So one of the things, the bullets that we have here, this really puts a very extensive ban on goods that are mined, produced, manufactured in whole or in part in the Xinjiang Uyghur Autonomous Region or also important, made with forced labor from the Xinjiang Uyghur Autonomous Region. There are instances of labor transfers from the region within -- from Xinjiang to other areas of China or even outside as part of the programs that are the Chinese Communist Party conducts in the region. So it's important to understand, it's not -- we're not just worried about things that come wholly from the Xinjiang Uyghur Autonomous Region or even partially, this is the possibility that workers from the region were involved in those goods. So again, the ban is comprehensive against that. There's also additional ability for the U.S. to impose sanctions on foreign entities that are affiliated with any forced labor action here. And again, at the end of the day, this act really effectively just assumes that any goods with a connection to the Xinjiang Uyghur Autonomous Region are made with forced labor. It does -- the act does specifically allow for an importer, a company to prove otherwise, but it's what we know, what we call the rebuttable presumption that this act holds up. The presumption is that the goods are indeed, if they're connected to Xinjiang in some ways, shape or form, they're connected forced labor. As an importer, you get the opportunity to rebut that, if your goods are somehow detained under the act. So under the act, there is a specific provision that allows for importers to request an exception if goods are detained. If CBP does grant an exception, then CBP is obligated to make a public statement on that and notify Congress. I believe there are a handful of exceptions in progress right now. Therese Randazzo will certainly speak to that during her section as to what's going on in the exception area, not a lot of activity so far there. As part of the act, there were conditions that were imposed upon certain government agencies. So the forced labor enforcement task force, which is headed by Department of Homeland Security, there are a number of other departments that are engaged in this. They were obligated to produce a strategy document, an entity list, a list of priority areas that the sectors, if you will, in the industry. So the areas of enforcement like cotton, tomatoes, polysilicon, were identified early on in the strategy. Besides the strategy document CBP also put together on their own, not under obligation under the act, but chose to put together an operational guidance for importers to kind of help importers get in line with the UFLPA and understand it. We have links to all of that, if you have not seen any of those documents at the end of this presentation. So you'll be able to take a look at that. And we're going to keep talking about this, again, through the course of today. Three key elements are essential for an importer to get an exception under the band. And so there has to be a determination by CBP that if a true exception for goods detained under the act is to be granted, there are 3 areas that CBP has to see. And first is that the importer of record is fully complied with the due diligence and evidentiary guidance and any associated implementing regulations that are established. So you've got to show, you've got your due diligence, and you've got your evidence in place in order. That's step 1. Step 2 is that you have to completely and subsequently responded to all CBP inquiries. So there's got to be a record of the importer engaging with answering questions, providing information, assisting with CBP's efforts to establish whether a specific group of goods that were detained are eligible for an exception. And then the most significant hurdle, which everyone acknowledges is a very substantial hurdle is the idea that you have to provide clear and convincing evidence to show that the goods were not produced wholly or, in part, with forced labor. And that is a substantial hurdle. Again, once if Customs CBP were to make a determination, then CBP has to notify Congress and explain why the exception was granted, and that's publicly available information. Besides asking for an exception, there's another scenario that importers may do if their goods are detained under the UFLPA, it's asking for an applicability review. So this is not a case where the goods are definitively from the Xinjiang region, and you're asking for an exception that they're not made by forced labor. This is a case where you're saying your goods really -- the UFLPA does not apply to your goods. There's no connection to the Xinjiang region. There's no connection to forced labor. The detention isn't appropriate under UFLPA. So this is a different thing. Again, Therese will spend quite a bit of time talking about exceptions request, applicability review request and what you need to be thinking about in there. The final thing that you'll hear us refer to the act in a number of different ways. So it's either the UFLPA, the act, the [ UFLPA], The Uyghur Act, you'll hear us speak about this in a number of different ways, but I assure you, we're talking about the same thing, the Uyghur Forced Labor Prevention Act. So Madeleine, let's talk a little bit about when goods get detained either under the UFLPA or under the legacy WRO provisions.

Yes. Okay. Thank you, Ted. Yes, so this -- we put this flow chart together, everyone. It was actually inspired by one of our customers. And we thought it's helpful as well to look at from a high level, what happens with this detention notice process operationally. And then the process to contest the detention, if that's what you choose to do. So again, this is at a high level, but kind of flows out how this process works. The red boxes are all CBP, customs activities. The blue boxes would be the importer and the light gray boxes would be the broker. So the process starts out on the lower left-hand side, where CBP is targeting, of course, high-risk commodities and entities. And then they may choose to issue an actual detention notice, whether that be a WRO or whether that be a UFLPA-detention notice. And that notice normally goes directly to the importer, and the importer would then notify the broker once they receive the detention notice. And then really, the importer then has to decide what do they want to do. So again, do they feel that they have enough documentation, sound documentation, complete documentation that they want to put an appeal together to advise customs, "Hey, I know I've got all my documentation in a row. I have everything I need. I know my goods were not manufactured by forced labor. I am going to put -- I'm going to contest this detention notice." Or the importer maybe -- may decide, "Hey, I don't have all my documentation yet together. I don't have all the pieces to tell a complete story. And I also don't want to wait for a CBP determination on all of this because I will be racking up the merge and detention. So I would rather just destroy the goods or reexport them." So this is the decision process that has to be made, and the importer will decide, "Hey, what do they wish to do." If they do want to destroy or export the goods, then you see the arrow that points back up to the broker because the broker can then arrange and help with either the destruction of the goods or the reexportation. Now if the importer says, "Hey, I have all my documentation, I'm going to put an appeal packet together." Then they will do so, and they will submit that packet to customs. Now with the WRO, you've got like 90 days to put that packet together. You will see Ted will talk about that further and Therese will as well with the UFLPA, you have 30 days. However, you can request an extension if it's a UFLPA detention notice from customs to have extra time if you choose to put a packet together. But once you submit the packet, the big question is how long will it take for customs to provide a response to the information that you have given customs. And in our experience, this can take a few weeks, but it can also take several months before CBP responds. And I think they're still working on the process, but it's not necessarily an immediate response. And so one thing as an importer that you have to factor in is the amount of time that you need to wait. And at that point in time, of course, you're probably racking up the merge and detention. So you need to factor that into whether you -- whether it's worth it. And whether you want to -- whether you're willing to wait and pay some demurrage and detention to put this packet, to provide this packet to Customs and wait on their response. Once Customs does make a decision, make a forced labor determination, they will notify, of course, you as the importer, and you would notify the broker. And then, of course, it can go 1 of 2 ways, of course. Either customs determined, "Hey, you've put a wonderful packet together. You've proven to me that there is no forced labor involved with the manufacturing of your product," So then they will just issue a customs release electronically. We as the broker would receive that release to ABI to the normal methods. And then we could arrange to obviously have the freight picked up and arrange the trucking. But of course, at that point, like I said, there would be probably, I'm sure, demurrage and detention to be paid as well. On the other side, though, you could also get a determination back from customer that says, "Hey, sorry, the packet you provided to me did not prove to me that these goods were not manufactured with forced labor. Therefore, we're going to exclude the product from being released into the commerce of the U.S." And at that point, you would have to destroy or reexport the goods depending on the scenario and probably still have demurrage and detention to deal with. So again, at a very high level, this is the process when a detention notice is issued. And so anyway, hopefully, that's helpful to give you an idea of what the process looks like. We can probably move to the next slide. Thank you. So one of the questions in this whole process and in putting an appeal or contesting the detention that we get at least I've received, and I think my colleagues have received this question over and over again is what is a good appeal packet look like? And at that point, importers aren't necessarily asking for all the details, but how does a good appeal packet? How is it constructed? What kind of, at a high level, what kind of information was included? And I think everyone has been asking that question. And so Customs recently came out with some very good guidance. They came out with 2 documents that I think were very, very helpful. One is called -- and this is under the UFLPA, though I think much of this could also be extended to a WRO or a finding, but Therese will go into more detail on that. But one of the documents that's called best practices for applicability reviews, what the importer responsibilities are. And then there is a second document called the guidance on executive summaries and sample table of contents, preparing a UFLPA applicability review submission, which gets into more of the details of what to do. So the best practice document, of course, highlights at a very high level, what importers need to do in terms of maintaining awareness. Understanding what is going on in the forced labor world, assessing your risk, preparing for a detention even if you haven't received a detention notice yet. Making sure you've got all your docs and documentation in a row. And then maintaining, of course, you're looking at your entire supply chain and communicating early. In the guidance document, there's a few points that I think are really, really helpful. One is when -- if you do get an detention notice, connecting with CBP as soon as possible, asking questions about the detention notice and determining next steps. So when you contact CBP, they may be able to provide more information about some of the information behind the detention notice. And then under UFLPA, you have 30 days, of course, to act on that, but you can request for an extension, which is very good. So you have to talk to CBP about that. And of course, as soon as you get the detention notice, talk to them if you need an extension because you're going to maybe put an appeal together. And then the admissibility packages or the appeal packages for CTPAT trade compliance partners, this is very important. Those are going to be prioritized at the center. So if you decide, "Hey, I'm going to put an appeal or a disability package together," and you are in CTPAT Trade Compliance, then that package is going to go to the front of the line, which is obviously a very important piece to note if you're putting one of these packages together. So this is -- these are just very high level, some highlights, but Therese is going to go into a lot more detail and give us some great information about these guidance documents and then some. So Therese, I'm going to pass the baton to you.

Thanks, Madeleine, and good afternoon, everyone. So yes, CBP has been busy in the last month or so with trying to put additional information out to importers to help them deal with the detentions under UFLPA as well as some other things that I'll just briefly touch on, and we'll come back to these a bit later. But in addition to the guidance that we -- can we go back to the preceding slide? Thank you. So in addition to the -- I'm going to focus this afternoon on the applicability review packages, and the best practices associated with those and how you approach contesting our forced labor detention more broadly because as has been said, many of those things were also applicable to admissibility reviews as well for under WRO and findings. But we've also, in addition to the best practices documents, we've also put out a new set of frequently questions related to UFLPA, an updated set of those as well as releasing a tool online or a dashboard to provide you with statistics on UFLPA enforcement. That's also useful as a risk tool. And then we've also recently held the Forced Labor Tech Expo to provide our platform and facilitate business-to-business communication on supply chain tools that might be helpful with regard to forced labor, and we'll come back to all of those later on in today's webinar. So can we move on now to the next slide. So just to recap, there's -- there have 2 options basically under UFLPA for contesting the detention, which of them you should choose or which you have to choose is dependent on the particular supply chain. So the statute forth [ sets ] forth the requirements for an exception. And basically, that applies to goods where the product is, in fact, so as whole year apart from the Xinjiang region of China or from an entity on the entity list. And if that's the case, your only option if you want to contest the detention is to meet the requirements for an exception. If you want to establish that the supply chain, in fact, does not touch the Xinjiang or does not involve the entities on the entity list, and that's the applicability review process. And that is much simpler because it's essentially supply chain tracing only as opposed to an exception where you have not only supply chain-tracing requirements, but you also have to demonstrate due diligence. You have to demonstrate supply chain measures such as internal controls, and you have to provide evidence that the goods were not made with forced labor. And as I mentioned, the bar for that is extremely high because it's a clear and convincing evidence standard that CBP must apply, in determining whether those requirements have been met. We do a lot more detail on all of those as available in the UFLPA strategy published by the forced labor enforcement task force that's turned by DHS. It is important if you were going to make an exception request, that you actually read that strategy and follow the guidance that is in there. CBP's operational guidance for importers of the UFLPA is a complementary document. And I know a lot of importers are used to focusing on the CBP documentation and the CBP requirements. But our guidance is really more operationally focused, and it does not completely or as fully capture what is in the actual UFLPA strategy. So just make sure that you're going to file an exception, that you're actually looking at the UFLPA strategy and those requirements. On the other side, if you're able to do an applicability review, and this arises because the UFLPA applies not only to goods actually produced in the Xinjiang or by net on the entity list that are exported directly to the United States, but it also applies to goods that are produced using any of those types of products as inputs, so that production can be done in other parts of China. It can be done in third countries and then those builder shipped to the United States. So we are looking not only at goods coming directly to the United States, but all from the Xinjiang or from the entity list, but also goods that are coming to the United States from other supply chains that are -- that we believe we have reason to believe are sourcing or involve sourcing from those parties. And so you sometimes get an applicability. You get shipments that become detained under UFLPA, where the goods are, in fact, not from the Xinjiang or from the entity list. But they nonetheless have been picked up in the targeting because it is inclusive, so that we can try to make sure that we are seeing what -- where we're setting that risk, and we're actually capturing things that are suspect. The other issue we have is that a lot of importers and we see this particularly in industries where there are not a lot of other good sources of supply, where they [ were imports ] to using a supply chain that the manufacturer does, in fact, use inputs from the Xinjiang in production. But is segregating those out and saying we're not shipping those goods to the United States. We're only shipping the ones that are not produced -- will go to Xinjiang to the United States. So from the CBP perspective, that's a high-risk chart -- supply chain because there's a large potential in many industries for co-mingling of those inputs. And I'll touch on that more in a little bit. So with an applicability review, you're essentially providing just the supply chain tracing documentation to demonstrate that, that supply chain does not involve inputs from the Xinjiang or the entity list. And the CBP operational guidance is very helpful in that regard because it does include additional information on supply chain tracing documentation, particularly in the priority sectors of polysilicon, tomatoes and cotton and cotton-made products. Next slide. So the first part of this is what kind of documentation is actually required if you're going to pursue an applicability review. And I'm going to focus on that because actually we have had relatively -- we've had so few exception requests so far that we're not really in a position to say what best practices look like overall there. But we have had enough applicability reviews that we can share, what has worked and what tends to streamline that process. So in an applicability review, you're endeavoring to document the ordering of everything. From the ordering of the product through the purchase of the manufacture and the transportation of inputs from the raw materials to the imported product. This is a key difference with UFLPA versus WRO and findings, is that you have to go back to the raw material and show that nothing was sourced from the Xinjiang. That's not the case where some with the WROs where the product is a gloves from Malaysia, and you only have to go to that first-tier supply. And because that is the entity that is subject to WRO, that is the product that's subject to the WRO. So this is a bit more complicated because there's the requirement to go back to raw materials. In that documentation, you need to identify all of the parties that participate in each transaction along that supply chain. So you have the raw materials in those parties and then you have the interim steps in the processing and those parties and then the final party who manufactures the goods that is shipped to the United States. So you need to identify all of those parties that are involved, and it's good to summarize what those parties do because we're not -- CBP is not as familiar with the supply chain is you would be or as your suppliers are. And so it's helpful to have a flow chart that summarizes what the supply chain is and the roles of the parties. Then you need to look at showing that the steps in that supply chain actually took place. So you would do that by showing that the movement of the payment for goods from between parties in the supply chain, and the movement of the goods in the opposite direction in that supply chain. So the actual transportation of those goods from one entity to another. And then for these transactions, you would want to provide the documentation that shows where the inputs came from. So the origin not only of the imported good, but also all of its components. I would note here that substantial transformation is not a factor. Once goods are tainted with forced labor, they remain tainted, even if they're substantially transformed into something else. So the traditional rules of origin are not quite as relevant here. The types of records that we're looking for are records that are kept in the ordinary course of business. So invoices and contracts and payment records, packing list, bills of [ late ] and the like. We were often asked, why don't we provide a very -- like a checklist of documents you need to provide, and we don't do that because that can actually work against you because CBP considers the totality of information that an importer provides. So we don't want to be in a situation where a failure to provide one document, where we might have otherwise let the goods go and release them, but you fail -- you didn't have one piece of information, one document. And so you didn't meet the requirements. And then the other issue is, of course, that supply chains vary not only among industries but within industries and sometimes even within companies. And so we don't want to limit what information you can provide in totality to show the supply chain does not touch the Xinjiang or an entity on the entity list. Next slide. So as you gather all this documentation, in the beginning, what we saw is a lot of people just gathered this documentation and they were just sort of dumping on CBP. That really slows the process down because then we're trying to wade through that and figure out what the significance of those documents are, how they fit together, et cetera. So this is some general guidance here on how to submit a package. The first thing being clear, complete and accurate is really important. And CBP will not review a package until it is complete. Because we look at the totality of information, we don't do reviews on a piece sale basis. So you really need to get the entire package in before the real review starts. So it's also -- I'd like the [Indiscernible] include English translations. The CBP generally is not able to. We're not able to do those translations and so if you assume it is documentation that is not in English, it's not very helpful, generally speaking. If you have a supply chain where you are importing goods, that -- and those goods come from a supply chain that is identical to one that CBP previously reviewed and released the goods, you do want to flag that when you submit the package to the center, and let them know that. Because once you get that track record going, you can accelerate the CBP review. It goes much faster because you don't have to provide as much information. You can provide a summary tracing report that outlines the suppliers and producers at Allstate. You're still to show the full supply chain and who all the suppliers in producers are at each stage. What you said to provide then you provide a business record that is associated with that production that will enable CBP to look back at the previous supply chain and see that these are the same, it's the same supply chain as was previously cleared and determined to be the goods were determined to be admissible and were released. I'll try to present the information in a format that is easy for CBP to read and understand. We do not have the expertise in your supply chain that you and your suppliers do. So given us a road map through the documents and pointing out what the -- how the flow of the supply chain and how the documents fit together is very, very helpful. If you need to make explanatory notes to the 2 documents that would in the package, do feel free to do that. Provide any additional information or context that you think will be helpful to CBP in understanding the package that you're submitting and following the supply chain, and then the steps and the parties and the records that you're submitting. If the supply chain is very, very complicated, your documentation is particularly complicated, then it's helpful to request a meeting with the center and actually walk the center team that's going to be doing your review through the documentation. That can simplify and streamline things as well, and it also gives us the opportunity to ask questions. And then if you are asked to provide any additional information, the faster you can do that, the better because as I mentioned, we're looking at totality of information. So not having the full package does slow the review process down. Next slide. So one of the documents that we recently published to accompany the best practices document for applicability reviews is also an executive summary and table of contents guidance document. And what this executive summary does is it's -- it helps CBP follow your supply chain and follow the doc and understand the documentation that you're providing. So it explains the documents that are in the package. So the first thing you'd want to do is provide an index or an annotated list of the documents that are in the package and you can number those so that they are for easier reference. But you would provide index, it can be done on the subsidy, they'd done in spreadsheets. We've seen it done in Word tables and variant flowcharts and various other forms, but you want to show the flow of that supply chain. Across the -- from the raw material all the way to the imported product, you'd want to connect each of those steps in the process. So if you say, "Here's the detention number, here's the entry it applies to, here's the bill of lading for the goods that are on this entry. Here's the purchase order for, say, the bill -- the goods that are on this bill," and so on through that process and link each of those documents together so that we can see that, again, the movement of the payment towards the suppliers and the goods towards you. And that those transactions have occurred both financially and physically. And then as I said, provide any sort of additional context for information that you think that would be helpful. Sometimes importers provide a slide deck that highlights key information. Sometimes they provide a tracing report that provides a summary of the manufacturing process. The centers are pretty knowledgeable, but sometimes you know that process better than they do. So it's good to provide them with that tracing report and how all of the steps fit together and who the parties are in each of those steps. Next slide. So in your package, a table of contents is also very helpful. So following your executive summary to have that table of contents. The list of documents in 2, 3 and 4 here are these are the types of documents that would be required for each step in the supply chain. So if you have a supply chain where you have multiple steps, or you have multiple suppliers at a particular step, which does occur. You might want to organize a sort of separate table of contents for each of those steps. So you would not say if you're talking about cotton products, you would have the raw cotton production and then the ginning and the yarn production, et cetera. So you would have a section for each of those steps in the supply chain. You would have a set of these documents, the 3 types of documents that I talked about, the parties in the transaction, the documents related to payment and transportation. And then the business were the supply chain records that a list -- that we have listed here. So your usual course of business type records on what we're looking for. Next slide. So we've been talking about what happens once the goods are already detained and how to contest the detention. But the time to start thinking about that is actually before the goods get detained, while you can request an extension of the 30-day detention period, if need be. It's better to be prepared in advance, if you're dealing with a high-risk supply chain where the possibility of detention is there. It's better to be prepared in advance and much easier to collect this documentation on the front end than it is to try to go back and get it after the goods have been obtained. So the first thing is risk awareness and being aware of as one of the earlier speakers said, what's happening in the forced labor space. So looking at the Department of Labor's list of goods produced with child or forced labor, looking at civil society reporting, academic reporting, media reporting. Other sources for now, like, for example, the CBP, UFLPA dashboard, which will give you visibility into the types of products that CBP is detaining and the countries that those products are coming from. It's also -- we suggest that looking at the our suppliers looking at the website in their native language, not in the -- necessarily the English versions for evidence of labor transfers and ties to the Xinjiang. This information used to be more frequently available on the English language websites for Chinese companies than it is now. They're neither -- some of them are not I'm not making that quite as public as it used to be on the website, particularly in English. And then assessed your risk and so you can make an intelligent decision about whether to import from that, so whether to continue using that supply chain or to be prepared for potential detention of those goods. So identifying manufacturers that are at high risk for using Xinjiang inputs. So a great example of this is, for example, in the solar industry, where there are very limited sources of supply from metallurgical-grade silicon. And so China really owns a lot of that market. So that supply chain is going to be high risk, so you know you should people have it in advance. And then do what you can to reduce vulnerabilities. If you can shift that supply chain to somewhere else or to different suppliers, that's certainly a good move to make if that's realistic and feasible from a business perspective. You need to be concerned not only with the risk posed by your immediate supply as for your Tier 1 suppliers, but also the risk posed by their suppliers. So you do need to go back and trace that supply chain back to make sure that the Xinjiang or the entity list does not appear in that supply chain. And then if you are in a situation where you are going to continue to use high-risk supply chain, so one that may involve goods that are -- I guess I mentioned there's a bifurcated supply chain where the suppliers are using goods in the Xinjiang, but they are not shipping those to the United States, but they're shipping into other parts of the world as much as for co-mingling. So you really need to make sure that you -- that they are segregating the Xinjiang and the non-Xinjiang imports and then those are not being co-mingled in that, that process is pretty -- is locked down. Because you're going to need to demonstrate that if the goods are detained and you want to contest that detention be on applicability review. So preparing it in advance, again, talking to the suppliers and making sure they are aware of requirements and are maintaining the appropriate documentation and let them know what types of documentation required. There is a bit of a challenge there, but because of the China Anti Sanctions Law, which [indiscernible] Chinese companies in a bit of a -- can put them in a bit of a difficult situation in terms of saying they are providing documentation specifically to help you contest the detention under UFLPA. So it may be better to just talk about in general, the meeting documentation, and visibility into the supply chain. Another thing to consider is trade secrets. Some companies may not be willing to share certain information with you, but if they're willing to share it directly with CBP, then those type of arrangements can possibly be worked out with the center so that they can receive the information directly. And then if you do have a supply chain that has passed, it has been reviewed and the goods have been released, consistency is helpful because those reviews will go faster in the future. CBP will continually reassess that risk. And so you may see some benefits from that. And you do -- so if you do have one of those types of supply chains, make sure you're informing the center and provided that summary tracing report that you have that ready to go. If you have a high-risk import coming in that you have -- you can be reasonably certain that it's going to be detained, based on past history or something like that. Then have that documentation package ready to go in advance and not waiting until you're in the detention [indiscernible] it's already detained. Okay. Next slide. So a couple of points about the actual detention process itself and the best practices that we've seen there. As Ted mentioned earlier, if you have questions about detention, contact the CBP POC in that detention notice soon, early on. If you're going to need an extension, request that before the 30-day initial detention period expires. You can request that via the Port Director or the Center Director, POC, that is on your detention notice. And then just noting again that if you are CTPAT Trade-compliant and your goods are detained, you need to point that out to the center, note to them that you are CTPAT Trade-compliant and that you're requesting prioritized review so that they will move your package to the front of the line when you submit it. Next slide. All right. Turning now to WROs and findings and the admissibility reviews that I've done with them. These are actually in many ways, very, very similar to the UFLPA applicability review in the sense that these are both general is that the admissibility reviews are general [indiscernible] they're always really supply chain tracing exercises. They're not establishing per se that the goods would not made with forced labor. They're showing that the goods are not sourced from the entity. The goods are not from the -- or not the goods that are targeted under the WRO, under the finding, they are not sourced from that entity. And this is -- these come up much more frequently in where the WRO, the finding, is on raw materials or interim products as opposed to final products that have been shipped to the United States, where it's very apparent to the manufacturer of the goods is, and whether those goods are subject to the WRO or the finding. So the best practices for applicability reviews under UFLPA in terms of the supply chain tracing documentation, those apply similarly to -- if you're seeking admissibility under WRO finding by trying to show that the WRO or the finding does not apply to your particular importation. These are also focused like as our applicability -- as on a specific shipment that is under detention, not more broadly, which sometimes there seems to be a little bit of confusion about that process. But these are always about a specific shipment that is under detention. And then on the other side of this, there is a broader process in the WRO and finding world for modification of the WRO or the finding itself because the WRO or the finding apply to all goods that all of the specified products that are produced by that manufacturer, regardless of who imported. So because sometimes, I hear WRO as referred to as specific to a shipment. They are not there specific to all product that is targeted under the WRO, it's not specific to a particular importation. And so the modification of a WRO or a finding is a good deal more complicated because, again, there has to be a demonstration that the goods were not made with forced labor. I've never seen an importer try to do this. It's technically possible, but I've never seen an importer try to do this, because generally, as an importer, you won't have sufficient documentation to demonstrate that all forced labor conditions have been remediated by that foreign entity, almost always the party petitioning for a modification of a WRO or finding is the entity who is producing the goods, that are -- or the subject of the WRO or the finding. It's all the -- that part pretty much always has to be involved because we will only modify WRO or a finding if it's demonstrated that all forced labor indicators have been remediated and the authorities no -- that entity is no longer using forced labor. But that does happen, and we like very much when that happens because that's our success because we no longer have -- there's no one production being made. So it benefits, obviously, the company's workers, but those goods are also allowed to be entered into the United States again. modification, which is a suspension of enforcement of the WRO or a finding is effective on the date of modification and applies to goods that arrive in the U.S. on or after that date. So if you have goods that were retained prior to the modification, those goods remain subject to the WRO finding, and you will have to establish that they're admissible. Those goods are -- those goods will not be released. And I know that doesn't seem that probably doesn't seem quite logical. So let me try another way of saying that. The WRO, the modification lifts the enforcement of the WRO or the finding against the goods that were subject to the WRO finding. With the applicability review, you sometimes -- you're basically what people are doing, what importers are showing is that their supply chain doesn't go to that party. They're not really shown that forced labor wasn't used. So those goods, you would need to demonstrate that they did not trace back to the party that -- they do not trace back to the goods that was subject to the WRO, to the party that -- let me use an example here, maybe that I'll make it easier. So we had a -- we had a finding on Sime Darby, for example, so that was recently modified. So if you had imported palm oil products, prior to the modification, you would have had to demonstrate that, that product did not come in any way -- wholly in part from Sime Darby. You would have to continue to demonstrate that after the modification was lifted because it applies only to goods going forward after that. So hopefully, that's clear. If not, I'm happy to answer questions about that. And with that, I'm going to turn it back over to Ted and to Brenda to talk a little bit about the 2 things that I mentioned earlier on that CBP has done recently to -- as a benefit to the trade community to try to be more transparent. The first is the dashboard on UFLPA statistics, which will enable you to get some risk information and see where and what types of products are being retained. And then the second is the Forced Labor Tech Expo, which CBP really served as a facilitator, they had to bring just to bring the business community together to look at the types of supply chain tools, and pricing technologies or testing technologies that are out there that might be helpful to importers who are contesting detentions. And so since these tools will build for the trade and for the benefit of the trade, I'm going to turn this back to Ted and Brenda to talk about those.

All right. Thank you, Therese. See, actually, you already covered a lot of it. So I think this will be quick for us. Just for everybody on the call, we still have almost 30 minutes left in this discussion. So we will move through our remaining content a lot of time for some question answering here. As Therese pointed out, the new dashboard was just released a couple of weeks ago. CBP has been providing statistics all along about Section 307, WRO enforcement actions, but the trade wars really interested if we could get specific statistics on UFLPA detentions and what countries and things like that. So this new dashboard is completely interactive. For those of you who work with tools like Microsoft Power BI or some other interactive data displays, this is exactly -- you should feel pretty comfortable with this. It's viewed as to the shipments that are detained under UFLPA, specifically, but it tells you the detentions, the country of origin, the industry sector of those detained shipments. The industry sector, you will find, is aligned by CBP's Center of Excellence, their center, the CE, as we call them. So for example, if you're an apparel importer, you would be part of the apparel, footwear and textile center of excellence. So you could click on the gray bar, for example, that says apparel, footwear and textile and the image on the left, and that will restructure and re-factor all of the statistics to give you the countries where shipments have been detained from the value of those. The shipments that have been released, things along that line. So I would just recommend quite simply going to the length that we provide as part of this presentation. And just start playing with it and click around, see what you do. I would say from my personal experience that I did look at the data dictionary that they link as well to the dashboard, gives you a view for the terminology and the things that are doing. But this is I think you'll find it interesting. You'll find it interesting. Therese highlighted this. We're not just seeing detentions from country of origin, China. You're going to see that actually detentions are coming from a number of other places. So it gives you a view as to some other countries where there are clear connections to the Xinjiang Uyghur Autonomous Region or people associated with it somehow in CBP's investigation. So really just take some time, click around and play with the dashboard and see what you think about it. And Brenda, you were at the forced labor Technical Expo, so tell us all about it, please?

I was. It was a really great 2 days. The CBP convened nearly 20, I think the count was 19 different solution providers that are working in the forced labor space earlier this month actually, I guess, it was March. So last month, at the Ronald Reagan Building, and they also provided the opportunity for live streaming. And just to give you a sense of the interest in the event. My understanding is that there were between 9,000 and 10,000 different views of those live stream presentations. Each of the solution providers was allotted about 15 minutes to present their solution. There were also several panels given by different Customs and Border Protection and Homeland Security officials, which kind of set the stage for why we're here, what we're doing and why this is so important. As well as gave a little bit of visibility into where the Department of Homeland Security, the Forced Labor Enforcement Task Force and the Customs and Border Protection, what their roles are as well as where they're headed next. So very, very good 2 days' worth of content. To try to distill the 2 days' worth of presentations, what I really saw is about 4 different types of solutions being discussed during the event. So there were several companies produced that were providing a supply chain mapping solution. And in many cases, that wasn't just a capture an importer supply chain, the data around an import supply chain. But there was also a form of risk assessment. And every company that presented these solutions took a slightly different approach. Most of the information was based not only on information available from the government, such as the Department of Labor, Customs and Border Protection, the forced labor strategy, things like that, but also captured nongovernmental organizations like the Sheffield Hallam reports and corporate record kind of assessment and translation, into a risk scoring algorithm and which was then applied or could be applied to a particular set of supply chain entities. There was also a real emphasis on the tagging and tracing testing, origin testing of commodities as they come towards the United States or to be used as a risk management strategy. And there were several solutions on the testing environment, and then several solutions also where specific commodities like cotton like pharmaceuticals, could actually be tagged in the early part of their production process and those tags would be sort of carried along. So for example, if you had cotton that was grown in India, that would be good to know so that you could use that indicator as evidence that your supply chain did not use their raw material from Xinjiang. Clearly, the expectation was that this would give the U.S. importing community. The opportunity to educate themselves on the art of the possible as well as start to think about what the options were, and what the parts of their toolbox needed to be in putting together a framework or an approach to be able to assure themselves that they had clean supply chains. And then to be able to show whether it's U.S. Customs and Border Protection or other countries around the world that have similar due diligence requirements, exactly what's going on in supply chains. I think the key point that the government made during the Expo was that there really isn't one single solution that can be applied to this very complex challenge. But in fact, it probably is a knitting together of the various tools and pieces of information, software, testing into one framework that would really give an importer good visibility and good confidence that they had a clean supply chain. CBP is also, in case you weren't able to attend that event, has also made the videos available. And if you are interested in a particular area of solutions, you can click on and in about 15 minutes, kind of get the high points of a particular product and use that as you work to build your own framework. Back to you, Ted.

Thank you, Brenda. So we do want to touch on quickly about this the customs trade partnership against terrorism and the recent requirements and criteria that have been added to the 2 CTPAT programs. So there are now specific -- there's specific verbiage in both of the programs that apply to importers who are either in the CTPAT security program. So that's the legacy CTPAT Program that's been around for 20 years or so, not quite. But this is the initial program that many people got into. If you're 1 of the 11,000-plus members in that core CTPAT security program, you have a minimum security criteria that became effective in the first of this year, that speaks to forced labor and that's it's under the business partner section. CTPAT members must have a documented social compliance program in place that, at a minimum, addresses how the company ensures goods imported in the United States were not mined, produced or manufactured wholly in part with prohibited forms of labor. So very much similar language that we're used to in the statutes we've talked about earlier. CTPAT, the team, did put out an alert very specific. It's a 7-page document. It's called Stopping Forced Labor in the Supply Chain. Again, click on the link. When you get this presentation, and this will -- it provides a lot of information, some resource documents, et cetera, that help you align with this. And then if you're a much smaller group, 1 of the 300 or so members that are part of the CTPAT Trade Compliance program, that used to be the importer self-assessment, the ISA. You need to be aware of requirements that are going to be coming effective in August of this year. So they're enumerated, the bullets on the right side of this slide. We're talking about our risk-based analysis of your supply chain partners that addresses factors posing a risk for forced labor a code of conduct statement against forest labor and that code of conduct statement does need to be uploaded into the portal. Evidence of implementation of the criteria we just talked about for CTPAT security. So the criteria applies also for CTPAT trade compliance. And you need to have a remediation plan, best practices. Those are the sort of things that CBP will ask for, but are not required to be uploaded. So again, if you're in the program, you need to be working towards this because these requirements will go into effect on the first of August. Final thing is CTPAT has made an effort to try to provide benefits to the trade compliance program members. So front-of-line admissibility review, opportunity to hold if CBP issues a redelivery notice due to a detention on forced labor, you can hold it at your facility. You're able to move goods held under a WRO to a bonded facility. So if you are in the CTPAT trade compliance program and you have goods detained either under UFLPA or WRO, please make sure and work with your CTPAT supply chain security specialist and the center of excellence expertise. Let them know who you are, so you can take advantage of those benefits. But again, make sure you're either all over the current criteria. If you're in CTPAT security or you are preparing for the trade compliance requirements coming due soon. Madeleine?

Thank you, Ted. And I'm not going to spend too much time on this, everyone we're getting towards the end. But just -- this was just to summarize what we are doing as expediters. Obviously, we're hosting like this webinar and sending out new splashes and any information that we come across that's been published on forced labor from CBP and from the other government entities. We are pushing out. One thing we're also doing operationally is we are keeping track. As we -- as our importers notify us of the detention notice that they received, we are keeping track of those at a high level so we can see where detention notices are being issued and for -- to whom and what the commodities are. And then we're just keeping our own internal statistics. And definitely, we can talk to you further about that if you're interested to learn more, just in general, what we are seeing. And then, of course, we do have Trade Win, our wholly-owned subsidiary. They are training on forced labor requirements. If you need additional training or you need help on specifically on WRO responses, they can help with that as well as looking at social compliance documents for forced labor language and CTPAT risk assessment and implementation and trade flow. Of course, it's a supply chain management tool with the large parts database that has also recently been updated with the postal code requirements for UFLPA. And obviously, is a supply chain tool that will screen for entities, for names and addresses, which we have in our core system as well. So anyway, I will -- we're happy to talk to you about this offline in more detail. And then just what you can do, of course, due diligence. And I think the largest or the biggest message, of course, is educating yourselves on forced labor. We're trying to do that on a daily basis. There is so much information out there, and we're going to be sending you the links to a variety of different publications that you need to really look at and everyone needs to educate themselves on in terms of forced labor. There's a lot of information out there, and we really do need to review much of it to get a full picture of what is going on. We do see many importers amending their language and contracts in order, orders in relation to forced labor. So we are seeing more and more of that. And obviously, you can't just focus on the seller of the goods anymore. You really need to understand the components -- know all the components that make up from the raw materials to the finished goods and what make up what your manufactured products. So knowing where those raw components come from, who makes those raw components, and how many of them are made up to make your final product. So again, it's a lot more digging that you, as the importer, need to do. This is not easy. You really have to be looking, of course, at your entire supply chain. You have to really keep an audit trail from a PO, invoice, payment, audit, production perspective, retaining all the records from the inception of the supply chain until the very end and really building a monitoring program that looks again at the entire supply chain. So we know this isn't easy. I would say, too, that just make -- I would just make 2 other notations here. One is the fact, what Brenda talked about with the Tech Expo. There's a lot of different software providers out there. Some of them provide some very interesting solutions, but there's not one tool that can help you with everything. So it's really kind of a stitching together of different controls. But definitely, it's worth looking at those videos if you weren't able to take part in the Tech Expo day. And then the other thing is just to be mindful of. If you're sending out questionnaires, especially to China to get to obtain more information from your suppliers there. Be careful, Therese mentioned this, too, earlier, be careful about making any reference to U.S. policies or to UFLPA as an example because there is the China Anti Sanctions Act and laws. And so you do have to be careful about that. So definitely consult with your legal department and be careful as you send out questionnaires, et cetera, to your Chinese suppliers. But we know as a whole, this is not easy. It takes a lot of work and you really have to be working diligently at this. Can't be -- it can't be done in a day. And there are a lot of good reference material resources and tools to help. And like I said, I think you probably have to stitch many of these resources and tools together to come up with an overall program. So the other thing I would say probably, you can go to the next slide because this really gives links. And again, this will be going out to all of you. Links to all the different information that's currently out there. And again, it's a ton, but it is really important that you begin looking at many of these, and familiarizing yourself with a lot of these documents. Some of them were referenced during the presentation such as the Sheffield Hallam University reports that are down there at the bottom, in the middle. There's the link to the dashboard that Ted was reviewing earlier. Anyway, there's a bunch of information here, but please make sure that you're looking at this. There's just -- this is a huge topic. And it's -- there's a lot of different information out there and you really have to familiarize yourself with a bit of all of it. So Ted, I think we can go to the next slide, which gives the NCBFA ACCS credit.

All right. So for those of you who are on this call that participate in the National Customs Broker Freight Forward Association of America on their certification programs, they have programs that are certification for custom specialists, export specialists and Master's program. If you're in one of those programs, we have attained accreditation for this today. So you have a continuing education requirement, maintain your certification. This webinar today is good for 1.5 continuing education credits, and you'll use completion code. You don't have to frantically try to copy the code. Again, we're going to provide the deck to you.

So with that, we're going to try to run through some quick questions, and I'm going to grab a couple of them just off the bat, to ask Therese to speak to a couple of things. One came up, and this should be a straightforward answer. "Can information in your package that you're using to contest detention. Can that be provided electronically through ACE, or is that something that's actually provided to the center? Or how would you go with that test?"

Some question. At this point in time, that can -- that's not being provided via ACE, I'm getting some echo in, I think. There are some -- we are having some -- we've had some issues with the package sizes. That is something we are working out how to get those packages submitted and the center can work with you on the best way to get that information to them. At this point, it's not like there's just like growing in the ACE portal and upload it. That's not quite -- we're not quite directly there yet.

Thank you. This look -- there are several variations of this, and that's a common question that I hear as well. So an importer, "I'm an importer, I get my goods detained, I choose to go ahead and just export the goods or whatever destroy them, what I'm going to do. Does that put a black mark on me? Does CBP start looking at me as an importer? How does CBP evaluate these detentions? Are we looking at importers? Are we looking at suppliers? Just again, the moment my goods get flagged, does that mean CBP is going to flag all of my goods for detention going forward because it's happened once?"

No. So a couple of things related to that. First of all, we do realize that importers sometimes up to export goods just for business reasons that it's either the goods are not worth the paying the storage and demurrage or the effort that it will take to get the documentation, or maybe you already know that you're not going to be able to get sufficient documentation from your suppliers. So we recognize that the exploitation can be -- it can be just a business decision. It's not necessarily an emissions that the goods are made with forced labor at all. Maybe it's just -- is not worth the time or the money that it would take to try to get the goods cleared. In terms of the targeting, the [ way we see ] 1307 and the UFLPA are directed at goods, not at the foreign entities, they're not directed importers. So we are looking at goods that are being produced overseas by who, and their potential nexus to the Xinjiang. So the fact that your goods have been detained and you decided to export them does not mean that, "Oh, the next time we're going to see you as a higher-risk importer." Where really the risk assessment is really more done against the foreign entities and the foreign brand and the goods that are being produced.

Perfect. Thank you. So a couple of questions around potential risk for Chinese suppliers involved in all of this and both Madeleine and Therese touched on this. I think I'll take this and just state. China absolutely denies that there's any forced labor activity in Xinjiang any other region of China. They clearly make statements about that. I read the People's Daily, which is the official newspaper of the Chinese Communist Party. I read it online pretty much daily. And there's typically an article about how wonderful life is in Xinjiang and very nice pictures and good things going on. And I don't mean this in any way other than the way the material is being presented by the CCP, the Chinese Communist Party. So in fact, there are articles, if you read the People's Daily, talking about how the U.S. is engaged in forced labor and persecution of people here. So China is adamant that there is no forced labor. They are basically putting their own material out for the public to see that they're not involved in any of this. This isn't happening. And as part of that, though, China has also passed specific laws like their Anti Sanctions Law that state that if you're a Chinese entity, you don't if you do indeed participate in something like the U.S.' enforcement actions and something along that line, China can issue their own sanctions against those entities. So this is why we pointed out if you are sending questionnaires to Chinese companies to your sourcing companies, we don't recommend that you use language around UFLPA or forced labor -- U.S. Forced Labor Enforcement Actions. You're doing this as part of your social compliance program, you're doing your supply chain tracing. You're doing a variety of things, but you want to be cautious about how you potentially could put your sourcing companies in China at risk. Anything further on that from any of my colleagues? Shaking up heads. We're all good. All right. Let's see here. What else is popping up. I don't know. Was there something Therese that you saw that was of interest as well as you're scanning this? I want to make sure we take advantage of you here. Go ahead.

Yes, just like let me take a quick look. It looks like there's quite a lot of questions here, actually.

So I think we've watched on a couple of things. I don't know -- does CBP offer guidance for importers to self-assess their risk. Therese covered a lot of the information that's there, and there are additional documents in the resources that we provided as well. Therese, I cut you off. I'm sorry.

Yes, yes, that's correct. There is -- there are a number of resources that are available as we're fairly exhausted list. It has expedited is provided at the end of the slide deck. There are additional resources on CBP's website. There are additional resources on the Department of Labor's website as well. Their comply chain application is particularly really going to establishing due diligence and for forced labor. So that's a good resource as well. And then I just did numerous things out there that talk about risk. Unfortunately, this is an issue that it can occur anywhere in pretty much any product. But yes, there are a number of resources that you can look to online.

A quick question: "Would CBP accept documentation such as invoices?" So this will be in a review of a packet to contested detention. "Would you accept documentation that had certain information redacted by the supplier?" So if the supplier doesn't want to share their cost for raw material or something like that, what do you think about that?

So it's hard to give a blanket response on that. Redactions are often problematic. So I don't want to give a yes, no, thumbs up, thumbs down, to redaction because it's very circumstance-specific, but generally speaking, reductions, you should try to avoid redactions.

Perfect. We're about running low on time. I do want to comment on one thing. Again, in the resources that we offered, you can go to the cpp.gov website and go to their forced labor web pages. They have several. There is a tool, a source. It's the [email protected]. It's right on the page, you can find it, but this is a fine way for you to ask questions to CBP, if we didn't get that answered by Therese today. A couple of questions, I'll do one quick one and then we'll cut over to Nicole to close this out. A lot of conversation about the requirement for the Chinese entity ZIP codes as that has gone into effect. If there is not a ZIP code in the entry file. So we're making entry for goods coming from China. And there is -- we are not provided a postal code. If we try to clear that entry, it won't work, it will reject. So please be very clear that hopefully, you're our customer, we've been working with you for the last several months about this, preparing for it. But please understand there has to be a ZIP code in that field in the electronic submission we make to CBP or it will just reject. We won't -- so it's not that your shipment is going to be detained or anything action is going to happen. We're not going to be able to process to that point for CBP to even detain the shipment. So with that, final comments, Therese, anything before we turn it over to close out? Since you're our guest, we'd like you to close things out for us, please.

I just want to thank you all, Expeditors team, for the opportunity to present at the webinar today. I think we've reached a lot of people. And hopefully, the information was useful and some of it, you're in the first year. So it was new because this is the first time we've actually talked about the applicability review packages in any depth. So hopefully, that information is useful to you all.

Thank you again, Therese. Definitely, I appreciate your specific personal engagement and certainly an engagement with CBP. So Nicole, close us out, so people can get on their day and watch the news as they're all frantically trying to watch.

Yes. Well, again, I just want to repeat what you said, Ted, and thank Therese and all the presenters for your time today, and all, everyone else who joined to participate in the webinar. As always, we appreciate your time, your questions and your continued support of our educational webinars. We will be hosting an Anti-Dumping Webinar in May. Stay tuned for the invite, that will be going out. And with that, I will let you all go, but thank you again for attending. Bye-bye.

And be safe out there, a lot of severe weather running across the U.S., so please be safe, keep your head down, pay attention to your local thunderstorm reports. But thank you again, everyone, for joining us today. We do appreciate it. Take care.

Thank you.

Bye-bye.