On 11 November 2024, the U.S. Customs and Border Protection (CBP) published new guidance on the use of isotopic testing for supply chain traceability, a tool with growing importance for importers seeking to access the U.S. market. This document, titled “Isotopic Testing Guidance,” details how this scientific method can be used to verify the origin of goods to help ensure they are not made with forced labour.
The Uyghur Forced Labor Prevention Act (UFLPA)
The UFLPA prohibits goods made wholly or in part in the Xinjiang Uyghur Autonomous Region (XUAR) from entering the United States. The UFLPA has made supply chain traceability even more critical for importers. Isotopic testing serves as a powerful tool for importers to trace and document their supply chains, preventing the import of goods potentially associated with forced labour.
What is isotopic testing?
Isotopic testing examines the unique atomic structure of materials, revealing a “fingerprint” influenced by the environmental conditions where a product was grown or produced. By comparing this fingerprint to a library of similar materials from different geographic regions, isotopic testing can determine if the tested material’s origin matches its claimed origin. The CBP utilises isotopic testing to evaluate risk in suspect supply chains, including shipments from the XUAR.
CBP’s guidance for importers using isotopic testing
- Selecting a test provider: The guidance outlines key factors for selecting a provider, such as adherence to best practices, accreditation under ISO/IEC 17025, the size and quality of their reference library, statistical modeling capabilities, and participation in proficiency testing programmes
- Testing methods: While no standardised method exists for isotopic testing, labs should be able to analyse stable isotope ratios using isotope ratio mass spectrometry (IRMS). Methods for isolating cotton from blended fabrics for testing should be clearly explained by the provider
- Test reports: The guidance details essential elements of a comprehensive test report, including a description and photographs of the product, claimed origin, analytical results, the method used, and a unique identifier. Importers should be aware that while a single report may apply to multiple shipments, it is the importer’s responsibility to demonstrate this connection with evidence like style numbers or purchase orders
Why use isotopic testing?
While not mandatory, isotopic testing allows importers to verify supply chains, demonstrate due diligence, and determine raw material sources. It can be a valuable part of a broader supply chain tracing and risk management programme.
CBP accepts isotopic test reports as evidence of origin. These reports, along with other supply chain tracing documents, can be submitted to the port of entry or the importer’s assigned Center of Excellence and Expertise.
The CBP’s “Isotopic Testing Guidance” is available on the CBP website and is a crucial resource for importers who want to understand and utilise isotopic testing. This document underscores the importance of this technology in promoting ethical sourcing and responsible supply chain management.
How Eurofins can assist
Eurofins offers comprehensive cotton origin verification testing to support importers in their UFLPA compliance efforts. Our services utilise advanced Stable Isotope Ratio Analysis (SIRA) technology to ensure the claimed origin of cotton is accurately verified. Our unique approach includes a dynamic reference library, expert interpretation, and tailored guidance to help clients navigate complex compliance requirements confidently.
Next steps
For questions and additional information on how Eurofins can support your organisation in verifying origin of products using isotopic testing, please contact Peter Hughes (peter.hughes@cpt.eurofinseu.com, +44 7542 857007) or Dr. Pratik Ichhaporia (pratik.ichhaporia@cpt.eurofinsus.com,+1-669-837-2257).
CBP UFLPA: Isotopic testing guidance document: https://www.cbp.gov/sites/default/files/2024-11/isotopic-testing-guide_11-08-24_eac_updatesfinal_v2_508.pdf
Eurofins Cotton Origin verification service: https://sustainabilityservices.eurofins.com/services/cotton-origin-verification-testing/
