Background

U.S. Customs and Border Protection has announced a new withhold release order that, effective Jan. 29, requires the detention at all U.S. ports of entry of coffee harvested by Finca Monte Grande, a Mexican coffee farm. CBP states that this WRO is based on evidence that workers at this facility are subject to six International Labor Organization indicators of forced labor.

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.

WROs are issued pursuant to 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 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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