Background

U.S. Customs and Border Protection has lifted an import ban on disposable gloves produced or manufactured in Malaysia by Top Glove Corporation Bhd after determining that they are no longer being produced or manufactured, wholly or in part, with the use of convict, forced, or indentured labor. This development highlights that company actions can effect changes in CBP withhold release orders and findings related to forced labor but that doing so can be a lengthy process.

CBP issued a WRO in July 2020 requiring the detention of subject gloves at all U.S. ports of entry following a determination that the information available reasonably but not conclusively indicated that these gloves were being imported in violation of the prohibition on goods made with forced labor. In March 2021 CBP replaced the WRO with a finding that the gloves were being made with forced labor and authorized port directors to seize and commence forfeiture proceedings against them.

However, effective with respect to goods imported on or after Sept. 10, 2021, CBP modified this finding to permit the importation of disposable gloves made at Top Glove facilities in Malaysia. CBP explained that Top Glove has addressed all indicators of forced labor, made more than $30 million in remediation payments to workers, and improved labor and living conditions at its factories.

Companies in all industries are being encouraged to conduct reviews of their supply chains as international scrutiny of the use of forced labor intensifies. 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. For more information, please contact David Olave (at (202) 730-4960 or via email), Amanda Levitt (at (212) 549-0148) or via email), or Nicole Bivens Collinson (at (202) 730-4956 or via email).

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