News & Analysis as of

Withhold Release Orders (WROs) Enforcement Actions Supply Chain

Foley & Lardner LLP

Real ESG Enforcement Mechanisms: Restrictions on Imports of Goods Made With Forced or Child Labor

Foley & Lardner LLP on

Many have viewed corporate commitments to ESG as largely performative measures amidst toothless compliance frameworks. But this has been changing and we expect that change to continue. One example arises out of the “S” in...more

Foley & Lardner LLP

Forced Labor Update — Possible Complete XUAR Import Ban

Foley & Lardner LLP on

On December 8, the U.S. House of Representatives passed the Uyghur Forced Labor Prevention Act nearly unanimously. The House bill would create a “rebuttable presumption” that all goods from the Xinjiang Uyghur Autonomous...more

Jones Day

U.S. Customs and Border Protection Seizes Two Shipments of Imported Products Found to Be Made With Forced Labor

Jones Day on

The risk of detention or seizure of products imported into the United States warrants renewed attention to responsible business practices on forced labor risk in global supply chains. United States Customs and Border...more

Foley Hoag LLP

First WRO of Biden Administration Targets Forced Labor on Chinese Fishing Fleet

Foley Hoag LLP on

On May 28, 2021, U.S. Customs and Border Protection (“CBP”) released the first Withhold-Release Order (“WRO”) of the Biden administration on seafood from Dalian Ocean Fishing Co., Ltd. (“Dalian”), a Chinese company, due to...more

Faegre Drinker Biddle & Reath LLP

Forced Labor Update: CBP Enforcement Actions Appear to Be Just the Start

Since August 2020, U.S. Customs and Border Protection (CBP) has initiated eight separate enforcement actions targeting goods from China’s Xinjiang Uighur Autonomous Region (XUAR) — none more sweeping than a January 13, 2021,...more

Clark Hill PLC

Increased Customs Enforcement Action on Cotton and Tomato Imports from China

Clark Hill PLC on

U.S. Customs and Border Protection (CBP) is aggressively enforcing the Withhold Release Order (WRO) on products from the Xinjiang Uyghur Autonomous Region (XUAR) of China. CBP issued the region-wide WRO on Jan. 13, based on...more

ArentFox Schiff

New Bills in Congress May Lead to Region-Wide Ban on Goods from Xinjiang Region of China

ArentFox Schiff on

Review Your Supply Chain and Establish Compliance Plans Because Forced Labor Laws are Here to Stay - If passed, these bills will grant US Customs and Border Protection authority for a region-wide WRO enabling the agency...more

Faegre Drinker Biddle & Reath LLP

'Know Your Supply Chains'— As to Forced Labor Enforcement, the Biden Administration is Picking Up Where the Previous...

In case there was any doubt as to where the Biden administration stands on forced labor enforcement, United States Customs and Border Protection (CBP) stated recently that its “message to the trade community is clear: Know...more

Sheppard Mullin Richter & Hampton LLP

CBP Stops More Imports Under Forced Labor Rules (Cotton a Jam, Part II)

On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) on cotton and tomato products produced by entities operating in Xinjiang, China. The order is based on information that...more

Akin Gump Strauss Hauer & Feld LLP

CBP Issues Region-Wide Ban on Xinjiang Cotton and Tomato Products

CBP has issued a “region-wide” WRO on cotton and tomato products “grown or produced” by entities “operating in” the XUAR. In a press release, CBP states that the order covers “apparel, textiles, tomato seeds, canned tomatoes,...more

ArentFox Schiff

CBP Begins 2021 With Expansive New Enforcement Against Forced Labor

ArentFox Schiff on

Just two weeks into CY 2021, US Customs and Border Protection (CBP) is expanding its enforcement efforts against forced labor in China. This follows months of increasing pressure from labor and human rights groups and...more

White & Case LLP

US Customs & Border Protection Enforces Forced Labor Prohibition in First Action Against Vessel

White & Case LLP on

A Taiwanese-owned, Vanuatu-flagged fishing vessel is the first known enforcement target of its kind by US Customs and Border Protection ("CBP") in its efforts to halt the importation of goods produced with forced labor....more

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