Background

Effective July 31, U.S. Customs and Border Protection removed subject goods imported from Lime Leaf Tobacco Company Ltd. from the scope of a withhold release order against tobacco from Malawi, which was issued in November 2019 based on reasonable suspicion that this tobacco is produced using forced labor and child labor. CBP states that this change follows a rigorous evaluation of LLTC’s social compliance program and efforts to identify and minimize the risks of forced labor from its supply chain.

This order continues to require the detention at all U.S. ports of entry of tobacco from Malawi by any company that has not demonstrated to CBP that there is no forced labor in its supply chain. 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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