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United States: A Loophole In CBP's Forced Labor Statute Just Closed, And Every U.S. Importer Should Take Note


On March 29, 2016, following on the heels of the elimination of the consumptive demand exception, CBP issued two detention orders based on information obtained by CBP indicating that a Chinese company and its subsidiaries utilize convict labor in the production of certain commodities. The commodities barred from import by these orders are soda ash, calcium chloride, caustic soda, viscose/rayon fiber, potassium, potassium hydroxide and potassium nitrate. The expectation is that CBP will follow these orders with published findings.