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A Review of CBP Actions on Forced Labor in 2020 and Outlook for 2021 | Foley Hoag LLP

To embed, copy and paste the code into your website or blog: 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 demand” clause of the Tariff Act, which previously allowed goods made with forced labor to enter the U.S. if they were needed to meet supply demands, WRO issuance has increased exponentially.

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