In a sign of the Administration’s ongoing crackdown on imports allegedly the product of forced labor, U.S. Customs and Border Protection has issued a September 14, 2020 press release announcing the issuance of five Withhold Release Orders (WRO) on certain products from China.

The products as identified by CBP (along with the associated rationale) are identified below:

1. All products made with labor from the Lop County No. 4 Vocational Skills Education and Training Center in Xinjiang Uyghur Autonomous Region, China. Information reasonably indicates that this “re-education” internment camp, which is often called a Vocational Skills Education and Training Center, is providing prison labor to nearby manufacturing entities in Xinjiang. CBP identified forced labor indicators including highly coercive/unfree recruitment, work and life under duress, and restriction of movement.
2. Hair products made in the Lop County Hair Product Industrial Park in Xinjiang Uyghur Autonomous Region, China. Information reasonably indicates this site is manufacturing products with forced labor of the Uyghur people and other minority ethnic groups who are detained in “re-education” internment camps in Xinjiang. CBP identified forced labor indicators including highly coercive/unfree recruitment, work and life under duress, and restriction of movement.
3. Apparel produced by Yili Zhuowan Garment Manufacturing Co., Ltd. and Baoding LYSZD Trade and Business Co., Ltd in Xinjiang Uyghur Autonomous Region, China. Information reasonably indicates that these entities use prison and forced labor in apparel production. CBP identified forced labor indicators including the restriction of movement, isolation, intimidation and threats, withholding of wages, and abusive working and living conditions.
4. Cotton produced and processed by Xinjiang Junggar Cotton and Linen Co., Ltd. in Xinjiang Uyghur Autonomous Region, China. Information reasonably indicates that this entity and its subsidiaries use prison labor in their raw cotton processing operations in Xinjiang. Cotton-processing factories and cotton farms in this region are prison enterprises that use convict labor.
5. Computer parts made by Hefei Bitland Information Technology Co., Ltd. in Anhui, China. Information reasonably indicates that Hefei Bitland uses both prison and forced labor to produce electronics. CBP identified forced labor indicators including abuse of vulnerability, restriction of movement, isolation, and intimidation and threats.

This action follows the August 31, 2020 filing of a petition seeking the issuance of a WRO on all cotton-made goods linked to the Xinjiang region of China (https://www.gdlsk.com/petition-filed-seeking-a-withold-release-order-on-all-cotton-goods-linked-to-xinjiang-region-of-china/) and various other developments on the legislative and other fronts.

Please do not hesitate to contact us with any questions on developments in this area or if we can assist your company in its due diligence efforts.