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Protecting Your Supply Chain: CBP Seizures of Goods Produced Using Forced Labor and Other US Government Enforcement Concerns

January 11, 2021
Arnold & Porter Webinar-of-the-Month Club for Retailers

While the United States has long banned imports of products made from convict, forced or indentured labor, a "consumptive demand" exception in the relevant law prevented vigorous enforcement. Since Congress repealed this exception, the Department of Homeland Security and US Customs and Border Protection (DHS/CBP) have issued numerous detention orders, including four in September 2020 against goods produced in Xinjiang (e.g., "labor" from an internment camp), and one broad order on November 30, 2020, against cotton and cotton products originating from the Xinjiang Production and Construction Corps (XPCC). Additionally, the US government has imposed numerous, diverse sanctions—export controls, financial sanctions and visa restrictions—in the last 12 months on Chinese persons and entities relating to the treatment of Uyghurs.

This webinar will provide an overview and history of the US law, an observation of DHS/CBP's investigation process, a discussion of the recent economic sanctions, and steps companies may consider when looking either to prevent or be prepared to respond to enforcement actions related to forced labor.


  • Recent CBP withhold release orders (WROs) addressing forced labor in China and elsewhere, including WROs related to the treatment of Uyghurs
  • Economic sanctions related to forced labor that have been imposed by Treasury, Commerce and State
  • Congressional actions related to forced labor
  • July 1, 2020 "Business Advisory" issued by the US Department of State, along with the US Department of the Treasury, the US Department of Commerce and the US Department of Homeland Security, that cautions businesses about the potential risks in supply chain that links to entities that engage in human rights abuses, including forced labor, in Xinjiang and elsewhere in China

Meet the Speakers

Samuel Witten
Arnold & Porter