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CBP Publishes FAQ Responses to Xinjiang Uyghur Autonomous Region WRO

By Jeffrey L. Snyder, David Stepp, Frances P. Hadfield, Maria Vanikiotis & John Brew on February 12, 2021
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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 seized if they were imported and/or received prior to the WRO being put in place?
  • Does the WRO apply to goods in a Foreign Trade Zone (FTZ) or warehouse?
  • Will CBP communicate detentions directly to importers or will it communicate with customs brokers? Will detention communications specify that the detention is because of the WRO or provide specific instructions to the importers on how to respond?

Proof of Admissibility

  • What guidance can CBP offer regarding proof of admissibility?
  • What evidence will CBP require from importers who have goods detained pursuant to the WRO to prove that the goods were not produced with forced labor?
  • If an importer has a shipment detained, who should importers work with to demonstrate their shipment is compliant? Should importers work with the port of entry executing the detention or the importer’s assigned Center of Excellence?

Due Diligence/Best Practices

  • What are best practices recognized by CBP for importers to ensure their suppliers are not engaging in forced labor?
  • How should importers ensure due diligence if they do not have a direct relationship with the upstream suppliers/manufacturers?

Miscellaneous

  • Will CBP allow importers to remove and enter goods that are not subject to the WRO from containers that include detained goods? What is the process for entering such containers?
  • Will CBP treat individual company information confidentially with respect to enforcement?

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

Forced Labor/U.K. Modern Slavery Act Archives | International Trade Law (cmtradelaw.com)

Xinjiang Archives | International Trade Law (cmtradelaw.com)

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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Photo of David Stepp 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…

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).

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Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

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Photo of Maria Vanikiotis Maria Vanikiotis

Maria Vanikiotis is a counsel in the International Trade Group of Crowell & Moring and resident in the firm’s New York office.

Maria has experience in a variety of matters related to the movement of goods across international borders, including problem-solving for importers

…

Maria Vanikiotis is a counsel in the International Trade Group of Crowell & Moring and resident in the firm’s New York office.

Maria has experience in a variety of matters related to the movement of goods across international borders, including problem-solving for importers facing Section 232 and Section 301 tariffs, classification of merchandise under the Harmonized Tariff Schedule, first sale appraisement programs, free trade agreement origin verifications, country of origin analyses, and other regulatory issues.

Before joining Crowell & Moring, Maria worked for a boutique law firm in New York focusing on customs law and, while in law school, Maria was employed as a summer associate in the Brussels office of a large international law firm on matters related to antitrust and competition law within the European Union. As a law student, Maria published a note comparing collective action approaches to antitrust cases in the U.S., U.K., and E.U., for which she won an award for outstanding legal writing. In addition, Maria was an active and accomplished member of both the Fordham International Law Journal and the Dispute Resolution Society.

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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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  • Posted in:
    Administrative and Regulatory
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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