CBP Enforcement of Forced Labor – Withhold Release Orders

Merchandise produced or manufactured in a foreign country using forced labor, including indentured labor and forced child labor is banned from importation into the United States. Section 307 of the Tariff Act of 1930 prohibits entry of these goods.

In 2018 CBP established a Forced Labor Division to lead the enforcement of the prohibition on the imports made with forced labor. Shortly thereafter, they began issuing Withhold Release Orders (WRO’s).  WRO’s  target products,  countries, regions and certain manufacturers. Statistics published by CBP on January 28, 2021 indicate 90 shipments have been detained between October 1, 2020 and December 31, 2020.

Today, political forces are increasing pressure on U. S. Customs and Border Protection to make a more concerted effort to stop these imports. The U.S. Senate Finance Committee recently held a hearing to identify how regulators can work together with industry to close any loopholes and find even more productive ways to identify imports made with forced labor.

It is expected that the Customs Trade Partnership Against Terrorism (CTPAT) plans to include Forced Labor in their Minimum Security Requirements.

Importers should review their procedures to address Forced Labor in their supply chain and help combat these abusive practices. More information on the forced labor program is available here.

You may also like to review previous posts on the subject of Forced Labor:

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