Camel Energy, a Michigan-based importer of lead-acid batteries, has recently filed a complaint at the Court of International Trade (CIT) contesting U.S. Customs and Border Protection’s (CBP) two recent exclusions of its shipments. CBP excluded these entries due to “suspicion of being made with forced labor and subject to the UFLPA.” Camel Energy maintains that these exclusions were unlawful.

The Uyghur Forced Labor Prevention Act (UFLPA) authorizes CBP to detain or exclude products made wholly or in part in Xinjiang or linked to entities included on the UFLPA Entity List. Camel Energy asserts that it is not on the Entity List, and its batteries are not produced with forced labor. Camel Energy’s parent, Camel Group, is included in the UFLPA Entity List and is challenging its designation at the Court of International Trade separately.

In its complaint, Camel Energy notes that CBP:

  • Excluded Entries Without Proper Evidence: CBP excluded two shipments “on suspicion” of forced labor, however Camel Energy claims CBP did not substantiate this suspicion or provide evidence.
  • Provided No Admissibility Determination: Camel Energy states CBP never made a formal admissibility determination for its entries, causing its protests to be denied by default after months with no decision.
  • Failed to Observe Response Deadlines: CBP allegedly did not give Camel Energy the required 30-day window to respond and prove the goods weren’t linked to forced labor or the UFLPA Entity List.
  • Lacked Notice and Transparency: Notices of detention and exclusion were sent days apart, with no explanation for this timeline. Camel Energy maintains that CBP failed to respond to its repeated requests for the evidence used against it.

The complaint highlights the broader issue of CBP’ s detention or exclusion of 95 separate shipments of Camel Energy’s batteries across multiple U.S. ports since August 21. Despite submitting responses and protests regarding most of these shipments, Camel Energy reportedly received no determination from the agency.

Camel Energy emphasized in its complaint that it has a “history of successful protests” against forced labor accusations in the past. The current lack of transparency and timely action by CBP, the company says, is deeply troubling, particularly due to the sudden exclusion notices and the absence of meaningful opportunity to respond.

This complaint highlights the challenges importers face under the UFLPA regime, especially pertaining to due process and evidence-sharing. Stakeholders in global supply chains, notably those dealing with products scrutinized under UFLPA, are watching the case closely for signals about future CBP enforcement practices and transparency.

Crowell & Moring will continue to monitor Camel Energy’s challenge at the Court of International Trade (Camel Energy v. United States, CIT # 25-00230)

Tags: Court of International Trade, Customs and Border Patrol, UFLPA, Uyghur Forced Labor Prevention Act
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Photo of Simeon Yerokun Simeon Yerokun

imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in

…

imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in the areas of business and human rights law, including compliance with global anti-forced labor and human rights requirements. He regularly represents companies before U.S. government agencies on forced labor-related matters, including securing the release of goods detained and seized by U.S. Customs and Border Protection. He also offers deep experience assisting companies in mapping their supply chains, including linking imported products back to their raw materials using enterprise software and other inventory management audit tools. Simeon is highly accomplished in forced labor supply chain mapping and risk assessments, as well as verifying due diligence efforts with on-the-ground visits to client facilities, incorporating third-party intelligence and audit resources.

Simeon’s experience also covers a broad spectrum of trade and customs issues, including those related to import regulatory compliance matters such as valuation, classification, duty drawback, marking and labeling, entry procedures, and penalties; free trade agreements; antidumping and countervailing duty issues; trade litigation; intellectual property issues such as trademark and copyright infringement; the enforcement of exclusion orders issued by the International Trade Commission (ITC); steel and aluminum tariffs under the Section 232 National Security Investigation; and the additional tariffs on products from China under Section 301 of the Trade Act of 1974.

Additionally, Simeon handles antidumping (AD) and countervailing duty (CVD) investigations before the U.S. Department of Commerce’s International Trade Administration (ITA) and the U.S. International Trade Commission (ITC) under the Tariff Act of 1930, and litigation involving the U.S. Court of International Trade (CIT).

Prior to joining Crowell, Simeon was a trade and finance attorney in the Office of Chief Counsel—U.S. Customs and Border Protection (CBP), and before that, he served as counsel to Commissioner Irving A. Williamson at the U.S. International Trade Commission.

Simeon is a proud graduate of Howard University School of Law, where he served as technical editor of the school’s Human Rights and Globalization Law Review.

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Photo of Pierfilippo M. Natta Pierfilippo M. Natta

Pierfilippo M. Natta (“Pier”), is an associate in Crowell’s International Trade Law practice. He focuses on assisting clients with complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier works on developing…

Pierfilippo M. Natta (“Pier”), is an associate in Crowell’s International Trade Law practice. He focuses on assisting clients with complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier works on developing Business and Human Rights legal guidance for clients and his practice covers a global reach including US, EU and Asia. His investigatory work has primarily focused on South-East Asia.

Pier applies his international trade knowledge to help clients identify manage and remediate risks. He has advised U.S. and global companies on developing programs specific to UN, US, and EU sanctions. More recently, Pier and the Crowell team are working to develop Crowell’s Business and Human Rights sub-practice which includes Crowell’s anti-forced labor investigatory work.

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Photo of Emily Devereaux Emily Devereaux

Emily Devereaux is a senior international trade analyst I in Crowell & Moring’s Washington, D.C. office. She provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and

…

Emily Devereaux is a senior international trade analyst I in Crowell & Moring’s Washington, D.C. office. She provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). She works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. She also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

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