Postal Code for Chinese Origin Goods Requirement
By NNR USA In USA Trade Alerts On 3rd November 2022
Updated March 20, 2023
Effective March 18th, 2023, U.S. Customs and Border Protection (CBP) will require a Chinese postal code data element declared as part of the Manufacturer Identification Number (MID) for goods made in China.
The new requirement is intended to provide early notification to importers that their goods may have been produced in the Xinjiang Uyghur Autonomous Region (XUAR). Goods produced in XUAR are subject to Uyghur Forced Labor Prevention Act (UFLPA) which automatically presumes the goods were made with forced labor.
A valid postal code will be required when the manufacturer's country of origin is reported as China.
Importers will be notified if:
- The postal code provided is not a valid Chinese postal code, or
- When an Uyghur region postal code has been provided.
All goods originating in XUAR are subject to detention upon arrival into the U.S.
Preparing for the New Requirement
Importers can prepare for the new requirement by verifying a valid Chinese postal code is included as part of the address listed on commercial documents for Chinese manufacturers and suppliers.
Can a Third-Party Seller or Invoice Party be used as the Manufacturer Identifier if the Country of Origin of the Product is China?
It depends. If the product is textile (19 CFR 102.23(a)) or has other agency requirements that mandate the actual manufacturer to be declared at time of entry, then the actual manufacturer name and address must be used. If no such requirement exists, then you may use the third-party seller or invoicing party as the manufacturer identifier.
What if my Supplier or Manufacturer's Postal Code is Located in the Xinjiang Uyghur Autonomous Region?
Your customs broker will receive a warning message and should notify you about the rebuttable presumption established by UFLPA.
Importers may request an exception to the rebuttable presumption from CBP during a detention, after an exclusion, or during the seizure process as described in the UFLPA Operational Guidance for Importers on Page 9. Importers may also submit information that the UFLPA is not in fact applicable to the imports that have been detained, excluded, or seized.
What Happens if Goods are Detained?
Shipments flagged due to a postal code located in the XUAR will be detained by U.S. Customs.
Importers will need to prove to CBP that their goods were not made with forced labor. See new resources posted by U.S. Customs for additional information.
Importers may also request an exception to the rebuttable presumption from CBP during detention, after an exclusion, or during the seizure process as described in the UFLPA Operational Guidance for Importers on page 9: UFLPA Operational Guidance for Importers | U.S. Customs and Border Protection (cbp.gov)
What is UFLPA?
The Uyghur Forced Labor Prevention Act establishes a rebuttable presumption that the importation of any goods, wares, articles and merchandise mined, produced, or manufactured wholly or in part in Xinjiang, or mined, produced, or manufactured by certain entities on the UFLPA Entity List, is prohibited by 19 U.S.C. § 1307, and that such goods, wares, articles, and merchandise are not entitled to entry into the United States.
Additional Information
CBP Trade User Information Notice, Uyghur Forced Labor Prevention Act Region Alert