https://rulings.cbp.gov/ruling/H318182
Uniqlo has provided evidence to establish that the raw cotton used to produce the subject cotton garments was sourced from entities outside of China, (specifically three (3) cotton suppliers in Australia, Namoi Cotton Alliance, Auscott Marketing Pty Ltd., and Queensland Cotton Corporation PTY LTD, three (3) cotton suppliers in the United States, J.G. Boswell Company, Bruce Allbright Agency Inc. and Allenberg Cotton Co. (a division of Louis Dreyfus Company LLC) and one (1) cotton supplier in Brazil, Agropecuaria Maggi Ltda.) ; however, Uniqlo has not provided substantial evidence to establish that the entities within the XPCC that processed that cotton into the subject goods did so without the use of forced labor.
In the detention letter issued January 5, 2021, the Port indicated that evidence such as “list of production steps and production record for the yarn, including records that identify the cotton and cotton producer of the raw cotton. Transportation documents from cotton grower to yarn maker. Supporting documents related to employee's that picked the cotton, timecards or the like, wage payment receipts, and daily process reports that relate to the raw cotton sold to the yarn produce.” would be required to establish that the subject goods were not produced by the use of forced labor.
However, our examination of the evidence submitted by Uniqlo reveals that it was not responsive to the Port’s request and does to establish that the subject goods were not produced using forced labor. Specifically, regarding the various entities within the XPCC that processed the subject cotton garments, there are substantial deficiencies: