On December 8, 2021, the U.S. House of Representatives passed a bill called the Uyghur Forced Labor Prevention Act (with a 428-1 vote) that bans the importation of goods produced using forced labor by Uyghers and other minority Muslim populations in the Xinjiang Autonomous Region of China. A similar measure has already passed in the

David Stepp
David Stepp is an experienced trade lawyer who provides multinational companies with strategic advice on global customs and international trade compliance matters. David is a partner in the Los Angeles office of Crowell & Moring.
His practice focuses on advising companies on their e-commerce strategies globally, conducting global customs and international trade audits, and assisting clients on improving, benchmarking, and coordinating compliance programs across borders.
David has over 30 years of experience handling international trade regulatory matters, including those related to tariff classification, valuation, country of origin marking, free trade agreements, and Customs-Trade Partnership Against Terrorism (CTPAT).
CBP Issues Forced Labor Withhold Release Orders on Malaysian Gloves and Mexican Tomatoes
On October 20 and October 21, 2021, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against disposable gloves from Malaysian company Supermax Corporation BHD and its three wholly owned subsidiaries as well as a separate WRO against tomatoes produced by Mexican farms Agropecuarios Tom S.A. de C.V., Horticola S.A de C.V.,…
Customs and Border Protection Publishes Trade Statistics Showing Increase in Enforcement Actions and Forced Labor Detentions
On August 26, 2021, U.S. Customs and Border Protection (CBP) announced that for FY 2021 between October 1, 2020 and August 6, 2021, the agency had detained approximately $368 million ($367,743,052) worth of cargo in relation to forced labor by issuing Withhold Release Orders (WROs). As noted by the agency’s trade statistics, this represented…
Federal Emergency Management Agency (FEMA) Announces Expiration of its Export Allocation Rule on Medical Supplies and Equipment for Covid-19
On July 1, 2021, the Federal Emergency Management Agency (FEMA) announced the expiration of its Temporary Final Rule (TFR) allocating certain health and medical resources for domestic use. The TFR – originally issued on April 10, 2020 and reissued for a second time on December 31, 2020 – prohibited surgical N95 filter facepiece respirators, personal…
CBP Issues Withhold Release Order (WRO) on Certain Silica-Based Products from Xinjiang, PRC
On June 24, 2021, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against Hoshine Silicon Industry Co. Ltd. – a silica manufacturing company located in China’s Xinjiang Uyghur Autonomous Region (XUAR) – and its subsidiaries on the basis of forced labor in the entity’s manufacturing practices. The WRO instructs CBP personnel…
CBP Publishes FAQ Responses to Xinjiang Uyghur Autonomous Region WRO
In light of increased U.S. actions and rising global concerns over reports of forced labor in Xinjiang, U.S. Customs and Border Protection (CBP) has issued the following Q&A responses:
General
- What is the scope of the Xinjiang Uyghur Autonomous Region (XUAR) Withhold Release Order (WRO)?
- Can imported goods within the scope of the WRO be
…
China Customs Targets Key Industries in Latest Transfer Pricing Enforcement Initiative
Transfer pricing is a major enforcement priority of China Customs in 2020. In April 2020, China Customs launched a national enforcement action to investigate and audit import transactions between related companies. More than 1000 multinational companies have received notices from China Customs requesting information on their transfer pricing policies and activities.
- Who will be impacted?
…
June 10 Webinar: United States – Mexico – Canada Agreement (USMCA)
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June 10, 2020
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The United States-Mexico-Canada Agreement (USMCA) – A Substantial Rewrite of NAFTA or More of the Same?
The USMCA will go into effect on July 1, 2020, and companies should immediately assess how their NAFTA compliance programs…
The White House Establishes “Forced Labor Enforcement Task Force” Under Section 741 of USMCA Implementation Act
On May 15, 2020, President Trump issued an executive order establishing the “Forced Labor Enforcement Task Force” required by the U.S.-Mexico-Canada Agreement (USMCA) implementing bill. Section 741 of the USMCA Implementation Act requires the Department of Homeland Security the Task Force as the central hub for the U.S. government’s enforcement of the prohibition on imports …
USMCA (NEW NAFTA) TO TAKE EFFECT JULY 1, 2020
The Office of the United States Trade Representative has notified the United States Congress that the United States-Mexico-Canada Agreement (USMCA) will enter into force on July 1, 2020. Following the notification to Congress, the United States became the third country to certify to the Parties (Mexico and Canada) that it had completed its domestic procedures…