U.S. Customs and Border Protection has issued a guide on the use of isotopic testing to help importers better understand their supply chains, demonstrate due diligence, and assist with determining the source of raw materials in final products.
Isotopic testing is a scientific method that identifies the atomic structure of naturally-occurring materials affected by local environmental conditions, and this guide addresses the use of light-stable isotopic analysis to verify the growing region of certain commodities or products, particularly cotton. CBP uses such testing to determine risk in suspect supply chains and to inform agency screening efforts on high-risk cargo, such as shipments from China’s Xinjiang Uyghur Autonomous Region (which are presumed to be made with forced labor under the Uyghur Forced Labor Prevention Act and are therefore excluded from entry into the U.S.).
CBP states that it is enhancing its isotopic testing capabilities at three of its laboratories (previously identified as being located in Savannah, Los Angeles, and New York), which will enable the agency to conduct more tests and obtain results more rapidly. However, even with these additional investments, CBP will not have the capacity to test all U.S imports.
As a result, CBP continues to encourage the inclusion of private-sector isotopic testing as one component of importer due diligence programs. Such testing should be conducted early, CBP states, because it is complex and time-intensive, requires sophisticated instruments and analysis, and does not produce instant testing results. However, CBP emphasizes that relying entirely on isotopic testing is neither feasible or effective.
The guide sets forth some considerations for choosing a test provider, discusses different methods of testing, and suggests data elements that test reports should include. CBP states that the recommended standards will ensure that tests conform to isotopic testing best practices and that origin testing conducted as part of due diligence has a higher likelihood of being more accurate.
For more information on using isotopic testing, particularly in the context of complying with forced labor import restrictions, please contact ST&R at supplychainvisibility@strtrade.com.
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