On May 28, 2020, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against Chinese fishing fleet Dalian Ocean Fishing Co., Ltd. (Dalian) on the basis of forced labor in the entity’s operations. The WRO against Dalian comes amid earlier WROs against other vessels in the distant water fishing industry—such as the Lien Yi Hsing No.12, the Da Wang, and the Yu Long No.2.  Notably, while these previous mandates targeted specific vessels, this is the first WRO to be issued against an entire fishing fleet. The WRO instructs CBP personnel at all U.S. ports of entry to detain all tuna, swordfish, and other seafood harvested by vessels operated or owned by Dalian.

CBP has indicated that Dalian Ocean Fishing Co., Ltd. is a major supplier to a seafood distributor. During a press briefing with Mr. Troy A. Miller, the Senior Official Performing the Duties of the Commissioner (SOPDOC) for CBP today (May 28), he indicated that this WRO also obviously covered downstream products from the fleet such as canned tuna and pet food.  Although the United States appears to be a lower priority market for Dalian, CBP data indicate that more than $2.9 million of the company’s seafood entered the United States between January 1, 2019 and April 30, 2021. This figure is broken down by calendar year in the table below.


Calendar Year Import Value
2019 $1,819,369
2020 $320,808
2021 (thru April 30) $763,115


The Agency’s Press Release identified all 11 indicators of forced labor, which include:

  • Physical Violence
  • Restriction of movement
  • Isolation
  • Intimidation and threats
  • Withholding of wages
  • Abusive living and working conditions
  • Abuse of vulnerability
  • Deception
  • Physical and sexual violence
  • Intimidation and threats
  • Excessive overtime.

WROs are issued by the U.S. government when information reasonably but not conclusively indicates goods were made in whole or in part using Forced Labor. Merchandise detained under a WRO order must be exported immediately or a substantial submission made that provides specific information showing that the goods were not made with forced labor. To obtain a release of any shipment that has been subjected to a WRO, a certificate of origin along with this detailed statement regarding the merchandise’s production and supply chain origin must be submitted to CBP. CBP makes a determination on a case-by-case basis.

The Press Release is available here.

For more information on actions addressing human rights and forced labor abuses, contact our team and see previous posts below.