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CBP Issues Palm Oil WROs Against Two Indonesian Producers: What Importers Need to Know 

U.S. Customs and Border Protection (CBP) issued two Withhold Release Orders against palm oil and its derivative products produced in Indonesia by Mitra Aneka Rezeki and Hardaya Inti Plantation, directing detention of that merchandise at all U.S. ports of entry. The orders reach any importer whose palm oil or palm-derived inputs trace to either producer. Importers of food, personal care, cleanings, and industrial products should confirm whether either company sits anywhere in their supply chain. 

KEY TAKEAWAYS 

  • CBP issued two Withhold Release Orders (WROs) covering palm oil and its derivative products produced in Indonesia by Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP). CBP stated that, effective immediately, personnel at all U.S. ports of entry will detain that merchandise. 
  • CBP cited nine International Labour Organization (ILO) forced labor indicators at MAR and seven at HIP. With this action, CBP stated it now oversees and enforces 60 WROs and eight Findings under 19 U.S.C. § 1307. 
  • Under 19 C.F.R. § 12.43, an importer contesting a WRO detention submits tailored certificates of origin from the foreign seller or owner and a detailed statement from the ultimate consignee within 3 months after the date the article was imported stating that no forced labor was used in making the product. DTL’s read: that record takes longer to build than the deadline allows if the work starts at detention. 

What CBP Announced

According to CBP’s […]

By |2026-10-05T08:24:41-04:00October 5, 2026|Enforcement, Forced Labor, Import, Supply Chain, U.S. Customs and Border Protection (CBP)|0 Comments
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2026 CBP Trade and Cargo Security Summit: Key Takeaways for Importers 

U.S. Customs and Border Protection (CBP) brought together government officials and members of the trade community in Dallas from September 8–10, 2026, for its annual Trade and Cargo Security Summit (TCSS). This year’s theme “Knowing Your Supply Chain to Remain Compliant and Mitigate Risk” was reflected throughout three days of discussions on enforcement, supply chain visibility, artificial intelligence, forced labor, transshipment, CTPAT, cybersecurity, and the future of customs compliance.  

Here are some of the most important takeaways for importers.

  1. CBP Is Entering a New Era of Customs Enforcement

A major focus of the Summit was the Administration’s June 3, 2026 “Strengthening Customs Enforcement” Executive Order and the regulatory changes expected to follow. 

The Executive Order calls for, among other things, heightened requirements for Importers of Record (IORs), expanded data and identification requirements, and increased vetting of IORs and other parties throughout the import process. CBP officials emphasized that implementation will be an agency-wide effort and that additional regulatory packages are expected.  

The shift is already visible in the government’s broader enforcement posture. Discussions at the Summit emphasized customs fraud, shell companies, identity theft, false importer information, double invoicing, and other schemes CBP is encountering in the trade environment. CBP also stressed that its focus is not on ordinary clerical mistakes, but on identifying and escalating consequences for parties intentionally exploiting the system.  

  1. Supply Chain Visibility Is Becoming a National Security Issue

Perhaps no […]

By |2026-09-18T12:55:44-04:00September 18, 2026|Best Practices, CTPAT, Enforcement, Forced Labor, Import, Supply Chain, U.S. Customs and Border Protection (CBP)|Comments Off on 2026 CBP Trade and Cargo Security Summit: Key Takeaways for Importers 
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China Blacklists Six U.S. Supply Chain Tracing Providers: What UFLPA Importers Need to Know

On August 5, 2026, China’s Ministry of Commerce placed six U.S. supply chain due diligence entities on its countermeasure list and prohibited organizations and individuals in China from transacting or cooperating with them. The six include the DNA tagging, isotopic testing, supply chain mapping, and labor audit providers that many importers rely on to document origin when U.S. Customs and Border Protection (CBP) detains goods under the Uyghur Forced Labor Prevention Act (UFLPA). Importers in cotton, apparel, electronics, minerals, and other UFLPA high-priority sectors should treat this as a direct hit on their evidence chain and act now. 

Key Takeaways 

  • On August 5, 2026, China’s Ministry of Commerce (MOFCOM) issued Order No. 2 of 2026 placing six U.S. entities on its countermeasure list under the Anti-Foreign Sanctions Law: Applied DNA Sciences, Inc.; Stratum Reservoir, LLC; Altana Technologies, Inc.; Responsible Business Alliance; Verite Group, Inc.; and Human Rights in China. 
  • The countermeasure prohibits organizations and individuals within China from engaging in relevant transactions, cooperation, and other activities with the six entities, effective August 5, 2026. The order imposes no asset freeze and no entry ban. 
  • MOFCOM’s spokesperson tied the package to the July 31, 2026 addition of 43 entities to the UFLPA Entity List, published in the Federal Register on August 3, 2026, which brought the list to 187 entities. 
  • The listed entities include providers of DNA tagging, […]
By |2026-09-09T12:19:28-04:00September 9, 2026|China, Forced Labor, Supply Chain, U.S. Customs and Border Protection (CBP), U.S. Department of Homeland Security (DHS)|Comments Off on China Blacklists Six U.S. Supply Chain Tracing Providers: What UFLPA Importers Need to Know
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USTR Announces Section 301 Action Imposing New Tariffs on 60 Trading Partners 

The Office of the U.S. Trade Representative (USTR) has announced a new Section 301 action imposing additional tariffs of 10% to 12.5% on imports from 60 economies that fail to prohibit or effectively enforce bans on goods produced with forced labor. The action covers the top 60 U.S. trading partners, representing 99.4% of U.S. imports, and took effect July 24, 2026. U.S. Customs and Border Protection (CBP) has issued entry filing guidance in CSMS #69326983, including the applicable Chapter 99 tariff headings. 

Key Takeaways 

  • Effective July 24, 2026, USTR imposed additional Section 301 duties of 10% or 12.5% on imports from 60 economies covering 99.4% of U.S. imports, based on findings that these economies failed to adopt or effectively enforce forced labor import prohibitions. 
  • CBP issued entry filing instructions in CSMS #69326983, including the Chapter 99 headings (9903.05.20 through 9903.06.21), reporting sequence, and Foreign Trade Zone admission requirements. 
  • Goods entered duty free under USMCA (Canada and Mexico) are exempt, as are CAFTA-DR textiles and apparel, Section 232 articles, civil aircraft, pharmaceutical articles, informational materials, and donations. There is also a list of miscellaneous products exempt no matter what their country of origin. 
  • An in-transit exception applies to goods loaded and in transit on the final mode before 12:01 a.m. ET on July 24, 2026, and entered before 12:01 a.m. ET on July 28, 2026. 

Why USTR Took Action

By |2026-07-24T10:11:00-04:00July 24, 2026|Forced Labor, International Trade, Tariffs, U.S. Customs and Border Protection (CBP)|Comments Off on USTR Announces Section 301 Action Imposing New Tariffs on 60 Trading Partners 
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CBP Issues Two New WROs Against Jordan Garment Factories: What Importers Need to Know

Why importers who diversified out of China to FTA partners are now squarely in CBP’s forced-labor crosshairs — and the five-step package you need before your first detention notice. 

Short summary: CBP just issued two Withhold Release Orders against garment factories in Jordan, a U.S. free trade agreement partner. If you diversified out of China, thinking that solved your forced-labor exposure, this action is your wake-up call. Duty-free status is not a compliance shield. For apparel and textile importers, the window to build a defensible admissibility package is now, before a detention notice arrives. 

On June 23, 2026, U.S. Customs and Border Protection (CBP) issued two Withhold Release Orders (WROs) against garments produced by Needle Craft Ltd. and Casual Wear Apparel LLC — two garment-manufacturing factories in Jordan. Effective immediately, CBP will detain all garments produced by these two factories at every U.S. port of entry. These are the fifth and sixth WROs of fiscal year 2026, and they push CBP’s active enforcement docket to 58 WROs and eight Findings under 19 U.S.C. § 1307. 

If you read only one sentence of this post, read this one: the country you moved your sourcing to to escape China-related forced-labor risk is not safe by virtue of being a U.S. trade-preference partner. Jordan Apparel enters the United States duty-free under the U.S.–Jordan Free Trade Agreement and […]

By |2026-06-23T12:22:55-04:00June 23, 2026|Forced Labor|Comments Off on CBP Issues Two New WROs Against Jordan Garment Factories: What Importers Need to Know
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Forced Labor Enforcement Just Crossed a Border: What CBP’s Serbia Copper WRO Means for Your Supply Chain

Key Takeaways 

  • CBP continues to chase the company, not just the country. Zijin’s parent was already on the UFLPA Entity List for forced labor in China; this Withhold Release Order (WRO) hits its Serbian copper operation on a separate evidentiary basis. Moving production to a “friendly” country does not move you out of CBP’s reach. 
  • Copper just joined the enforcement map. Forced-labor detentions are no longer concentrated in apparel, solar, and cotton. If you import copper—or anything containing it—your supply chain is now in scope, and most copper-reliant importers have done zero forced-labor due diligence. 
  • The burden is on you, and it lands the moment your shipment is detained. Under a WRO, there is no notice and no grace period. You either prove your goods are clean by detailed documentary evidence, or you export or destroy them. 

On June 16, 2026, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order against copper and copper products manufactured in Serbia by Serbia Zijin Copper D.O.O.—the fourth WRO of Fiscal Year 2026 and the second targeting a Serbian operation in roughly six months. Effective immediately, CBP personnel at every U.S. port of entry will detain shipments of copper and copper products from this company. 

If you read that as another distant enforcement headline, you are missing the part that should concern you. This […]

By |2026-06-19T13:16:26-04:00June 19, 2026|Enforcement, Forced Labor, Supply Chain, U.S. Customs and Border Protection (CBP)|Comments Off on Forced Labor Enforcement Just Crossed a Border: What CBP’s Serbia Copper WRO Means for Your Supply Chain
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CBP Just Rewrote the Forced Labor Rulebook: What the New Operational Guidance Means for Importers

Short summary: On June 9, 2026, CBP issued new guidance supplementing its 2022 UFLPA guidance and other resources with a single document covering every forced-labor authority it enforces. The new guidance outlines CBP’s detention and exclusion processes and gives practical guidance on how to respond.

On June 9, 2026, U.S. Customs and Border Protection (CBP) published its new Forced Labor Enforcement Operational Guidance for Importers (Publication No. 5560-0526). It is not a refresh. It updates the June 13, 2022, UFLPA Operational Guidance for Importers and, for the first time, consolidates all forced-labor enforcement authorities CBP wields into a single 89-page reference. 

That consolidation is the story. Until now, importers had to stitch together separate sources to understand how the Uyghur Forced Labor Prevention Act (UFLPA), Withhold Release Orders and Findings under 19 U.S.C. § 1307, and the Countering America’s Adversaries Through Sanctions Act (CAATSA) actually differ in practice. CBP has now mapped all of them — including the exact timelines, the review paths, and the documentation bar — in one place. The practical effect: ignorance of the process is no longer a defensible position. 

The one-line summary every importer needs 

CBP detains or excludes goods it suspects were made, wholly or in part, with forced labor — and the burden is on you to prove they weren’t, on a clock that can […]

By |2026-06-17T10:00:55-04:00June 17, 2026|CTPAT, Enforcement, Forced Labor, Import, International Trade, U.S. Customs and Border Protection (CBP)|Comments Off on CBP Just Rewrote the Forced Labor Rulebook: What the New Operational Guidance Means for Importers
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U.S. Department of Labor Introduces New Tools to Support Supply Chain Integrity and Address Unfair Foreign Labor Practices

On April 8, 2026, the U.S. Department of Labor (DOL) announced the launch of several tools to empower U.S. companies to strengthen their supply chains and defend against unfair competition stemming from overseas labor abuses.

Self-Assessment Tools

DOL launched four voluntary self-assessment tools that provide practical, user-friendly guidance to help companies map supply-chain risks and evaluate labor practices. The tools can also guide companies in taking steps to ensure alignment with U.S. forced labor laws and strengthen supply chains that support American workers and American industry.

The new tools are: 

  • LaborShield: A mobile app that features information on egregious labor violations in over 145 countries (formerly the Sweat and Toil app).
  • ImportWatch: A resource that brings together the department’s labor abuse research with U.S. import data from the U.S. Census Bureau to produce a red-flag list of all high-risk goods for U.S. importers.
  • SourcingStrong: A tool to help U.S. businesses build strong labor due diligence systems to identify and manage risk in their supply chains.
  • Supply Chain Traceability Portal: The portal provides visibility across supply chains and beyond the first tier to expose where exploitative labor hides.

Announcement Insights 

Diaz Trade Law was in attendance at the launch event in Washington, D.C. – hosted by the DOL and […]

By |2026-04-09T16:06:27-04:00April 9, 2026|Enforcement, Forced Labor, Import, Supply Chain, U.S. Department of Labor (DOL)|Comments Off on U.S. Department of Labor Introduces New Tools to Support Supply Chain Integrity and Address Unfair Foreign Labor Practices
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Section 301 Investigation into Forced Labor Practices — US Allies and FTA Partners Under Scrutiny

On March 12, 2026, the United States Trade Representative (USTR) published its Initiation of Section 301 Investigations into the practices of various economies, including that of US allies and long-standing trade partners, for their alleged failure to prohibit the importation of goods produced with forced labor.  

What Can the USTR Do? 

Section 301, formally known as Title III of the Trade Act of 1974 or “Relief from Unfair Trade Practices,” authorizes the USTR to investigate acts, policies, or practices that it considers unreasonable, discriminatory, or burdensome to US commerce. The USTR goes on to say that practices which permit forced or compulsory labor meet the criteria of unreasonable, unfair, and inequitable. If the USTR concludes that an act is “unjustifiable” and “burdens or restricts” US commerce, action is mandatory. On the other hand, if the USTR determines that such act is only “unreasonable or discriminatory” and “burdens or restricts” US commerce, action is discretionary. In either case, when the USTR aims to remedy a foreign trade practice, the agency can (1) impose tariffs or other import restrictions, (2) withdraw or suspend trade agreement concessions, or (3) enter into a binding agreement with the foreign government to either cease the conduct in question or compensate the US. Additionally, the statute requires that when USTR’s action is mandatory, the agency’s action should “affect goods or services of the foreign country in an amount that is equivalent in value to the burden or restriction […]

By |2026-03-19T08:58:32-04:00March 19, 2026|Forced Labor|Comments Off on Section 301 Investigation into Forced Labor Practices — US Allies and FTA Partners Under Scrutiny
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CBP Launches New Forced Labor Portal 

On January 21, 2026, Customs and Border Protection (CBP) launched its new Forced Labor Portal. The Portal provides a central system for submitting review requests for shipments detained or excluded for forced labor enforcement.

Effective, January 21, 2026, importers MUST use the portal to submit the following for review:

  • Withhold Release Order/Finding admissibility reviews.
  • Uyghur Forced Labor Prevention Act applicability reviews.
  • Uyghur Forced Labor Prevention Act requests for exception; and
  • Countering America’s Adversaries Through Sanctions Act exception requests.

All detained or excluded shipments requiring review must be submitted through this Portal, and users must have a login.gov account to access it. Depending on the type of review submitted, submission will be reviewed by CBP personnel in Forced Labor Division, or Port of Entry, or the Center of Excellence and Expertise.

Diaz Trade Law has confirmed with CBP that responses to CBP Form 28 (Request for Information) and CBP Form 29 (Notice of Action) should not be submitted through the Forced Labor Portal.

The Portal is available at https://flportal.cbp.gov/s/login/ and CBP has provided an instructional video on how to submit a request here.

This change reflects another step forward in how CBP interacts with the trade community, transitioning from […]

By |2026-01-29T08:26:07-05:00January 29, 2026|Enforcement, Forced Labor, Import, news, U.S. Customs and Border Protection (CBP)|Comments Off on CBP Launches New Forced Labor Portal 
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