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UFLPA and doll collecting

Jun 17, 2022

    1. UFLPA is the Uyghur Forced Labor Prevention Act, and CBP (Customs and Border Patrol) intends to fully implement the law starting June 21, 2022.

      In short, UFLPA presumes that anything produced in the Xinjiang Uyghur Autonomous Region (XUAR) is the product of forced labor and will not be permitted into the US. This means any goods - in whole, or in part. And the "in part" bit is what I believe is going to affect doll collectors.

      Per this link, XUAR was forecasted to produce 70 percent of the world's calcium carbonate - also known as talc or silica. Calcium carbonate is a common polyurethane resin filler and is used for mold release.

      XUAR is also a huge exporter of human hair, both natural and synthetic, textiles (cloth and clothing), yarn, footwear, and toys. Quote from the linked article:
      "More specifically, China’s share of global exports includes 30.5 percent of apparel, 41.9 percent of textiles and rags, 46.7 percent of cotton fabrics, and 10.9 percent of cotton yarn. China is the world’s largest producer of yarn, textiles, and apparel, and one of the world’s two largest cotton producers."
      I am tracking this law for work, and I attended a CBP webinar on it. CBP is taking a hard line on anything, and I mean ANYTHING, coming out of XUAR. Requests for exemptions (granted only if the importer can prove that nothing in the item was manufactured using forced labor) have to be reported to Congress within 30 days and will be published publicly. The strong implication is that exemptions are going to be granted sparingly, if at all. *Edited to add: per the CBP presenter, if they open a box and see the words "Made in China," they are going to hold the items until the importer can provide paperwork showing that nothing used to manufacture the item was sourced from the XUAR. I see this as a de facto ban on all imports from China.

      Other countries have passed similar laws. It is my prediction that starting 6/21/2022, US imports are going to grind to a halt. And that may very well include dolls, wigs, and doll clothing.

      *edited to correct errors
       
      #1 MaleficentMrsofEvil, Jun 17, 2022
      Last edited: Jun 18, 2022
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    2. Forced labor is terrible. I'm glad that they are trying to do something about it, but still. Just makes me wonder if there is a better way.

      Anyways, thank you for the information! I will definitely keep an eye on this thread.
       
      • x 1
    3. Oh.....this is....concerning.

      Admittedly, I am very far from expert on this subject. This is the first I've heard of it. I wonder what kind of effect it will have on the hobby. Obviously, I would hope that none of our dolls are made by forced labor. I just always kind of assumed that these sorts of things are created by artists, being small companies or individual people creating them. I hadn't considered how the materials are made.

      From the sounds of it, every single product coming from the XUAR area would be prohibited unless specifically exempt? How would they be able to trace where the item's materials were made? That seems like an awful lot of research they'd need to do on each individual package coming into the US. Will things from other parts of China still be allowed? How many of our doll/accessory companies are in this area? And how will this affect our doll artists who are working entirely by free will, but are in the area? How could we continue to support those legitimate businesses?
       
      • x 5
    4. Forced labor is horrible. That said, it's exceedingly unlikely much of anything will change; the DPRC has zero interest in owning up to any and all human rights violations, and will no doubt forge, loophole, and gaslight their way past everything per usual.
       
      • x 2
    5. This is very interesting. I too wonder, if this is the best way to go about it though.

      It seems like the amount of evidence required to really prove that even the smallest part of the goods to be imported had nothing to do with forced labor could be…problematic? And it might affect small companies and individual sellers more than big companies, which could still find loopholes and continue to sell their products to US buyers.

      I thought so too. I didn’t consider that how the resin is made or that even mold release could pose a problem. It all still seems relatively unclear unfortunately. “Customs is still developing guidance on what evidence would be sufficient”.

      They’re supposed to publish a list of banned companies and more details on June 21st. Hopefully, BJD companies will be able to provide enough evidence for their products to be allowed into the country, but again, I do hope it doesn’t end up being something that takes up such a large amount of paperwork, time and money to sadly make small BJD companies want to give up altogether.

      I obviously also sincerely hope none of the companies we’ve all been supporting have ever used forced labor (-related materials). It would be a real shame to see any of them lose such a big part of their business due to unclear requirements or even just the process going too slow for them to keep their businesses running.
       
      • x 2
    6. Update, or lack thereof:
      I have emailed Denver Doll Emporium, BJDivas, and Alice's Collections (BJD dealers) regarding this issue - especially since I have orders for dolls with Dream Valley and Impldoll (both Chinese companies). I have not received any response yet.

      If anyone's doll has been blocked by US Customs, I think it would be helpful for the rest of us to know.
       
      • x 1
    7. i'm also worried about my outstanding impldoll order and keeping an eye on this thread to see what happens :(
       
      • x 1
    8. Now I am even more hesitant to buy a brand new doll.
       
    9. I was also about to buy a doll from DZ, so China as well. :pout: I don't know if I should just not buy it at this point, until we know more at least...They just had a sale on a doll I've wanted for a long while.
       
      • x 1
    10. I'm sad to hear about the forced labor/cruel practices in these areas. And I think it would have been obvious to creators that we wouldn't want our dolls (or any product) to have that kind of that kind of history. So hopefully, they have put together the proper documentation.

      Today is the day that they start limiting these imports so I don't think we will get a record of the denials for a few months as the ships start to come in. :( I do hope that everyone can get their dolls. :eusa_pray
       
      • x 1
    11. For what it's worth it seems like the enforcement will be targeted to a specific list of manufacturers, most of which seem to be textile-focused, according to their FAQ + linked list:

      How will CBP enforce the Uyghur Forced Labor Prevention Act rebuttable presumption?

      CBP will employ a risk-based approach, dynamic in nature, that prioritizes the highest-risk goods based on current data and intelligence. Currently the highest-risk goods include those imported directly from the Xinjiang Uyghur Autonomous Region, or Xinjiang, into the United States and from entities on the UFLPA Entity List. CBP will also prioritize illegally transshipped goods with inputs from Xinjiang, as well as goods imported into the United States by entities that, although not located in Xinjiang, are related to an entity in Xinjiang (whether as a parent, subsidiary, or affiliate) and likely to contain inputs from that region.​

      The US ending trade with China over human rights violations is one of those hypothetical "this will never happen because it'll destroy the global economy and start WW3" situations I was taught about in school, so finding out that it's going to happen via doll forum is putting me through a bit of a rollercoaster to say the least...:nowords:
       
      • x 7
    12. happy to report that my order from Impldoll shipped out from China on July 24th and was delivered to me today (July 30). no problems, issues, or unusual delays in customs. i know there was another US collector in the impldoll waiting room with me who also got their order yesterday with a similar lack of issues.
       
      • x 2
    13. I received an order from Granado mid July, and no issues with customs. It was shipped with a China based shipping company (SFExpress), not through the US postal system.
       
      • x 2
    14. @kurogane Impldoll is also using SFExpress; that's the company that handled my order too.
       
      • x 3
    15. I should also add that, although off-topic, I received some discontinued Mattel playline dolls I ordered off of AliExpress without any problems.
      So far, so good...
       
      • x 3
    16. i just received my Popodoll Phoenix (1/3 sized) with Yanwen as first carrier, and USPS inspected it in customs (special sticker time), still only eleven days in transit, which seemed positive :thumbup they'd pulled the head out of the bag, i'm thinking classic magnet check.
       
      • x 2
    17. We've not encountered any issues with our AliEx orders being delayed or not showing up.
       
      • x 2