Background

U.S. Customs and Border Protection has announced a new withhold release order that, effective Dec. 18, requires the detention at all U.S. ports of entry of automobile tires manufactured in  Serbia by Linglong International Europe D.O.O Zrenjanin.

CBP states that this WRO is based on its identification of nine forced labor indicators during its investigation of this company, including intimidation and threats, excessive overtime, withholding of wages, abusive living and working conditions, and deception. CBP said it gathered evidence from worker statements, photographs, employment contracts, focus group field notes, text message screenshots, open-source non-government organization reports, news media, and academic research.

According to CBP, importers of detained shipments may seek to destroy or export those shipments or demonstrate that the goods were not produced with forced labor.

This action brings to 55 the number of WROs CBP is enforcing, along with nine findings, under 19 USC 1307, which prohibits imports of goods made wholly or in part with forced labor, including convict labor.

Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address forced labor concerns around the world, including supply chain reviews, due diligence strategies, and proactive remediation. 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 supplychainvisibility@strtrade.com.

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