## UFLPA Burden of Proof: The 30-Day Detention Clock
### The Rebuttable Presumption The Uyghur Forced Labor Prevention Act (UFLPA, Public Law 117-78, effective June 21, 2022) establishes a **rebuttable presumption** that any goods mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region (XUAR) of China are made with forced labor and are prohibited from entry into the United States.
**The presumption is rebuttable** — but the burden of proof falls entirely on the importer, not on CBP.
### The 30-Day Detention Clock When CBP detains goods under UFLPA: 1. **Day 0:** Goods detained. CBP issues detention notice. 2. **Day 1–30:** Importer has 30 days to submit a "supply chain package" demonstrating the goods were not produced with forced labor. 3. **Day 30:** If no package submitted, or package insufficient, goods are **excluded** (refused entry). 4. **Post-exclusion:** Importer can appeal to CBP's Office of Trade within 30 days of exclusion notice.
### What the Supply Chain Package Must Contain CBP has published guidance requiring the package to include: - **Complete supply chain mapping** from raw material to finished good (every tier, every facility) - **Facility audit reports** for all production facilities (ILO-compliant third-party audits) - **Worker interview documentation** (demonstrating freedom of movement and voluntary employment) - **Import documentation** (commercial invoice, bill of lading, packing list, certificates of origin) - **Traceability documentation** (lot codes, batch records, production records)
### The Reality: Months-Long Port Freezes In practice, assembling a complete supply chain package for goods with Xinjiang-origin components takes **3–6 months**, not 30 days. Most importers: - Cannot obtain facility audit reports from Chinese suppliers within 30 days - Cannot conduct worker interviews remotely - Do not have tier-2 and tier-3 supplier mapping
The result: goods are excluded, then tied up in appeals fo...