U.S. Customs and Border Protection (CBP) recently posted answers to the most frequently asked questions regarding the withhold release order (WRO) aimed at silica-based products from China. These answers outline the scope of the Hoshine WRO by detailing the types of information that CBP may seek to determine whether forced labor was involved in an imported good. If an importer claims that forced labor is not involved, then they “‘must submit the Certificate of Origin signed by the foreign seller’ and a ‘detailed statement from the importer.’” It is important to note that “a standard Certificate of Origin is not acceptable.” The required format is detailed in 19 C.F.R. § 12.43(a).
The FAQs aim to elaborate on how CBP will be administering the WRO. If you have any questions regarding CBP’s answers please reach out to Mohawk Global Trade Advisors.