Background

U.S. Customs and Border Protection has issued a new withhold release order that, effective Nov. 23, requires the detention at all U.S. ports of entry of raw sugar and sugar-based products produced in the Dominican Republic by Central Romana Corporation Limited. This WRO could have significant consequences for U.S. companies that import or use such sugar since the DR is a major supplier to the U.S. market and Central Romana is the country’s largest producer.

Importers of detained shipments will have an opportunity to export their shipments or submit proof to CBP that they were not produced with forced labor.

Earlier this year more than a dozen members of the House of Representatives requested that CBP, the Office of the U.S. Trade Representative, and the Department of Labor jointly review longstanding allegations of forced labor in the DR sugar industry and then identify and consider all policy tools available to address them. The new WRO represents one such action and follows a CBP investigation identifying five of the eleven International Labor Organization indicators of forced labor in this industry. Other steps taken earlier this year include the DR’s inclusion on the Department of Labor’s most recent list of goods produced by child labor or forced labor and its placement on the Tier 2 list in the State Department’s most recent report on human trafficking.

One measure that has not yet been imposed, but potentially could be, is a limitation on the eligibility of goods imported from the DR for duty-free treatment under CAFTA-DR, which requires beneficiary countries to enforce their labor laws as one condition for such treatment.

Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address forced labor concerns, 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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