U.S. Customs and Border Protection (CBP) has published answers to a set of frequently asked questions regarding the withhold release order (WRO) that was issued Jan. 13. The WRO was aimed at cotton and tomato products made with slave labor in the Xinjiang Uyghur Autonomous Region (XUAR).

The WRO also includes downstream products produced outside the XUAR that incorporate these inputs. Examples of products include apparel, tomatoes, tomato sauce, and other goods made with cotton or tomatoes. Importers are responsible for ensuring the products they are attempting to import do not exploit forced labor at any point in their supply chain. 

The FAQs page answers several questions about the scope and application of the WRO, proof of admissibility, due diligence/ best practices, and several other miscellaneous questions. The FAQs page also clarifies that the WRO applies to covered goods entered from a foreign-trade zone or warehouse on or after Jan. 13.

The FAQ page also recommends using several resources to understand and address the risks of forced labor in global supply chains including:

For further questions, please reach out to Mohawk Global Trade Advisors.