U.S. Customs and Border Protection on Aug. 3 provided new details to the trade community on the movement of forced labor detained cargo for storage.

The agency states that importers or their authorized filers may submit a request to the port director at which their cargo is detained pursuant to 19 U.S.C. 1307 to move their detained cargo to a customs bonded warehouse for storage pending resolution by CBP or the importer. The port director has the authority to approve or deny the request and will do so based on the circumstances at their port. If the port director approves the request, where appropriate, the importer or their authorized filers can update the entry type from a formal entry (e.g., Entry Type 01) to a bonded warehouse entry (Entry Type 21). If on the other hand the port director denies the request, then no changes should be made to the original entry.

CBP adds that importers or their authorized filers may not move detained goods suspected of being made with forced labor into a foreign-trade zone for storage.

Sandler, Travis & Rosenberg has a robust program to assist companies on forced labor issues. ST&R also maintains a frequently updated web page offering a broad range of information on forced labor-related efforts in the U.S. and around the world. For more information, please contact ST&R at

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