A Review of CBP Actions on Forced Labor in 2020 and Outlook for 2021

Withhold Release Orders (“WROs”) are a key part of Customs and Border Protection’s (“CBP”) efforts to enforce the Tariff Act, which prohibits the importation of merchandise mined, produced or manufactured, wholly or in part, by forced labor, including prison labor. CBP issues WROs upon evidence that reasonably – but not conclusively – indicates that a product is made with forced labor. After issuance, such products are blocked from entering the U.S. Since the repeal in 2016 of the “consumptive...
By: Foley Hoag LLP

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