Effective Dec. 5 U.S. Customs and Border Protection began detaining goods produced or manufactured by three Chinese companies following an agency investigation indicating that they are violating the Countering America’s Adversaries Through Sanctions Act by using North Korean labor in their supply chains.

According to CBP, CAATSA prohibits the entry of goods, wares, and articles mined, produced, or manufactured wholly or in party by North Korean nationals or North Korean citizens anywhere in the world unless clear and convincing evidence is provided that such goods were not made with convict labor, forced labor, or indentured labor under penal sanctions. 

Pursuant to this law, CBP said it will detain goods from the three companies at all U.S. ports of entry unless there is clear and convincing evidence that forced labor was not present at any stage of the production process. If such evidence is not provided within 30 days of the notice of detention the goods may be subject to seizure and forfeiture.

Any person or organization that has reason to believe that goods in violation of CAATSA, or any goods produced with forced labor, are or are likely to be imported into the U.S. can submit detailed allegations through the e-Allegations Online Trade Violations Reporting System or by calling 1-800-BE-ALERT.

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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