Background

Effective June 3, CBP removed subject goods imported by Alliance One International from the scope of a withhold release order against tobacco from Malawi and products containing such tobacco, which was issued in November 2019 based on information indicating that this tobacco is produced using forced labor and forced child labor.

This order continues to require the detention of all other such goods at all U.S. ports of entry. Importers of detained shipments have three months to either export their goods or provide a certificate of origin and detailed statement demonstrating that the goods were not produced with forced labor. If no such documentation is provided, or if it does not establish admissibility, the goods are subject to seizure.

CBP encourages stakeholders to closely examine their supply chains to ensure that imported goods are not mined, produced, or manufactured, wholly or in part, with prohibited forms of labor; i.e., slave, convict, forced child, or indentured labor. A list of all CBP withhold release orders and findings is available here.

For more information on these or other withhold release orders and how they may affect your business, please contact Nicole Bivens Collinson or Elise Shibles.

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