Effective for goods imported on or after Feb. 3, U.S. Customs and Border Protection is again allowing shipments containing palm oil or derivatives thereof produced by Sime Darby Plantation Berhad in Malaysia to enter U.S. commerce.

In January 2022 CBP issued a finding that Sime Darby and its subsidiaries were using forced labor to produce palm oil and derivatives on plantations in Malaysia and that such goods were likely being imported into the U.S. As a result, CBP authorized its port directors to seize and commence forfeiture proceedings against the following products unless the importer established by satisfactory evidence that they were not produced in any part with the use of forced labor.

- palm oil and derivative products classified under HTSUS 1207.10.0000, 1511.10.0000, 1511.90.0000, 1513.21.0000, 1513.29.0000, 1517, 3401.11, 3401.20.0000, 3401.19.0000, 3823.12.0000, 3823.19.2000, 3823.70.6000, 3823.70.4000, 3824.99.41, and any other relevant subheadings under Chapters 12, 15, 23, 29, and 38 that are produced or manufactured wholly or in part by the Sime Darby, its subsidiaries, and joint ventures

These measures applied to not only palm oil but also derivative products made in whole or in part from palm oil, which include cereals, baked goods, chocolate, coffee creamers, margarine, cosmetics, methyl ester and hydrodeoxygenated biodiesel, glycerin, mono- and diglycerides, propylene glycol, tocopherols, and palmitate, among others.

CBP has now modified its finding based on satisfactory evidence that Sime Darby, its subsidiaries, and joint ventures no longer produce palm oil and its derivative products using forced labor.

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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