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CBP’s Region-Wide WRO Escalates Pressure in China’s Xinjiang Region

On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a withhold-release order (WRO) on all cotton and tomato products from China’s Xinjiang Uyghur Autonomous Region (XUAR) based on information that reasonably...more

U.S. Expands WROs in Xinjiang, Targeting Major Cotton Producer with Implications for Global Supply Chains

On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an import detention or Withhold Release Order (WRO) against cotton produced by Xinjiang Production and Construction Corps (XPCC) based on information that...more

U.S. Government Moves to Block Imports from Xinjiang, Triggering Due Diligence Challenges for Companies

On September 14, 2020, U.S. Customs and Border Protection (CBP) issued five Withhold Release Orders (WROs) for a range of goods produced in the Xinjiang region of China.  Under 19 U.S.C. § 1307, CBP can initiate enforcement...more

Treasury and CBP Temporary Rule on 90-Day Deferment for Payment of Certain Duties

On April 19, 2020, the Treasury Department in conjunction with Customs and Border Protection (CBP) released a temporary interim final rule (“Rule”) to provide importers that meet the qualifying criteria with the option of a...more

Temporary FEMA Rule: Export Approvals Required for Certain Personal Protective Equipment

On April 7, 2020, the Federal Emergency Management Agency (FEMA) released for public inspection a temporary rule that prohibits the export of five types of personal protective equipment (PPE) without explicit approval by...more

DHS’s New Criminal Enforcement Initiative to Prosecute Corporations for Forced Labor

Criminal investigations will target businesses profiting from the importation into the United States of goods made using forced labor. The new criminal enforcement initiative seeks to leverage data about corporate supply...more

Slavery in Supply Chains: CBP Petitions Raise New Forced Labor Compliance Risks

Third-party petitions seeking to ban the importation of goods made with forced labor may affect global supply chains. Petitions are being filed with U.S. Custom and Border Protection seeking to ban the importation into the...more

U.S. Customs and Border Protection Takes Action Against Fishing Vessel Under Forced Labor Import Ban

On February 4, 2019, U.S. Customs and Border Protection (“CBP”) issued a withhold release order (“WRO”) against tuna and tuna products from the Tunango No. 61, a Taiwanese vessel, based on information obtained by CBP that...more

CBP Takes Measures to Enforce Ban on Imports Made With Forced Labor and Sanctions for Forced North Korean Labor in Supply Chains

On November 22, 2017, Apple, Inc. (“Apple”) released a statement confirming reports that its major supplier in China, Foxconn Technology Group (“Foxconn”) has used illegal student labor to assemble the latest version of the...more

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