17 months since it’s last issuance of a Withhold Release Order (WRO), U.S. Customs and Border Protection (CBP) revives its enforcement mechanism to target a Chinese importer and its affiliates operating in the safety products industry.

Effective Wednesday, April 10, 2024, U.S. Customs and Border Protection (CBP) will detain work gloves manufactured by Shanghai Select Safety Products Company, Limited and its two subsidiaries from China, Select (Nantong) Safety Products Co. Limited and Select Protective Technology (HK) Limited. CBP personnel will detain these products at all U.S. ports of entry and detained shipments will be excluded or subject to seizure and forfeiture if proof of admissibility is not presented to CBP by the importer.

Shanghai Select Safety Products Company, Limited and its two subsidiaries were issued a Withhold Release Order (WRO) by CBP due to evidence of use of convict labor. WROs are a tool to combat forced labor and other human rights abuses throughout the world, emphasizing to foreign suppliers that forced labor is not welcome in supply chains in the United States. This WRO is now one of fifty-two overseen and enforced by CBP.

The WRO issued on April 10, marks CBP’s first WRO targeting a Chinese entity since the entry into force of the Uyghur Forced Labor Prevention Act (UFLPA). To put matters into perspective, in fiscal year 2023, CBP issued one WRO and modified one finding and three WROs. The move to re-target Chinese importers follows Executive director of Trade Remedy Law Enforcement Directorate at CBP, Eric Choy’s statement in an interview during the CBP Trade Facilitation and Cargo Security Summit where he mentioned he expected there to be a WRO to be announced before October.

Tags: China, Customs, Forced Labor, UFLPA, Uyghur Forced Labor Prevention Act, Withhold Release Order, WRO
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Photo of John Brew John Brew

John Brew is the co-chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office. He has extensive experience in import and export trade regulation, and he regularly advises corporations, trade associations, foreign governments, and non-governmental organizations…

John Brew is the co-chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office. He has extensive experience in import and export trade regulation, and he regularly advises corporations, trade associations, foreign governments, and non-governmental organizations on matters involving customs administration, enforcement, compliance, litigation, legislation and policy.

John represents clients in proceedings at the administrative and judicial levels, as well as before Congress and the international bureaucracies that handle customs and trade matters. He advises clients on all substantive import regulatory issues handled by U.S. Customs and Border Protection and Immigration and Customs Enforcement, such as classification, valuation, origin, marking, tariff preference programs, other agency regulations, admissibility, import restrictions, quotas, drawback, audits, prior disclosures, penalties, investigations, Importer Self Assessment and Customs-Trade Partnership Against Terrorism programs, importations under bond, the Jones Act, vessel repairs, and foreign trade zone matters.

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Photo of Pierfilippo M. Natta Pierfilippo M. Natta

Pierfilippo M. Natta (“Pier”), is an associate in Crowell’s International Trade Law practice. He focuses on assisting clients with complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier works on developing…

Pierfilippo M. Natta (“Pier”), is an associate in Crowell’s International Trade Law practice. He focuses on assisting clients with complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier works on developing Business and Human Rights legal guidance for clients and his practice covers a global reach including US, EU and Asia. His investigatory work has primarily focused on South-East Asia.

Pier applies his international trade knowledge to help clients identify manage and remediate risks. He has advised U.S. and global companies on developing programs specific to UN, US, and EU sanctions. More recently, Pier and the Crowell team are working to develop Crowell’s Business and Human Rights sub-practice which includes Crowell’s anti-forced labor investigatory work.

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