Background

U.S. Customs and Border Protection has announced a new withhold release order that, effective Sept. 24, requires the detention at all U.S. ports of entry of bicycles, bicycle parts, and accessories manufactured in Taiwan by Giant Manufacturing Co. Ltd.

CBP states that this WRO is based on its identification of the following forced labor indicators during its investigation of this company: abuse of vulnerability, abusive working and living conditions, debt bondage, withholding of wages, and excessive overtime. CBP asserts that the company “profited by imposing such abuse, resulting in goods produced below market value and undercutting American businesses by millions of dollars in unjustly earned profits.”

According to CBP, importers of detained shipments may seek to destroy or export those shipments or demonstrate that the goods are admissible.

CBP states that this action brings to 53 the number of WROs the agency is enforcing, along with nine findings, under 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 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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