On July 26, 2021, U.S. Customs and Border Protection (CBP) modified its July 1998 Withhold Release Order (WRO) that originally prevented the importation of carpet and hand-knotted wool products from seven Nepalese companies. Specifically, CBP modified the WRO so that carpet and hand-knotted wool products from Annapurna Carpet Industries Pvt. Ltd. (Annapurna Carpet) would be admissible at all U.S. ports of entry. This decision came after a thorough investigation by CBP into Annapurna Carpet indicated that the company had addressed all eleven indicators of forced labor and “remediated concerns about the use of forced labor in its production process.”

The modification marks the second time CBP has modified this WRO. The first time CBP modified the WRO was in October 1998 when it allowed for the importation of carpet and hand-knotted wool products from the following three of the seven companies originally included in the WRO:

  • Norsang Carpet Industries Pvt., Ltd.,
  • Everest Carpet
  • K.K. Carpet Industries.

At that time CBP found that the three companies had fully addressed concerns regarding the use of forced labor in their supply chains. Notably, the following three companies are still impacted by the WRO:

  • Kumar Carpet Pvt.
  • Singhe Carpet Pvt.
  • Valley Carpet

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.

CBP Issues Withhold Release Order (WRO) on Certain Silica-Based Products from Xinjiang, PRC | International Trade Law (cmtradelaw.com)

Customs and Border Patrol (CBP) Issues Withhold Release Order (WRO) Against Chinese Fishing Vessels | International Trade Law (cmtradelaw.com)

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Photo of John Brew John Brew

John Brew is the former chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office.

John has extensive experience in import and export trade regulation, collaborating with corporations, trade associations, foreign governments, and nongovernmental organizations on…

John Brew is the former chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office.

John has extensive experience in import and export trade regulation, collaborating with corporations, trade associations, foreign governments, and nongovernmental organizations on customs administration, enforcement, compliance litigation, legislation, and policy matters. He 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. John 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, customs brokerage, Section 321, drawback, foreign trade zones, duty recovery programs, import restrictions, quotas, audits, prior disclosures, penalties, investigations, Customs Trade Partnership Against Terrorism and trade compliance programs, importations under bond, the Jones Act, and vessel repairs.

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Photo of Jeffrey L. Snyder Jeffrey L. Snyder

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of…

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of U.S. extraterritorial regulations. Jeff assists companies in day-to-day compliance with these laws, and with interventions — such as audits and investigations, and civil enforcement proceedings.

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