When the United States Customs and Border Protection (CBP) announced withhold release orders on Oct. 1, the mainstream media gave it considerable coverage. The orders implicated Costco Wholesale Corporation and Ansell, both with supply chains in Asia allegedly tainted by forced labor.

Pajamas made for infants and sold by Costco^[1] were allegedly manufactured by ethnic minorities in China forced to work in an internment camp, while rubber gloves sold by Ansell were allegedly manufactured by a Malaysian company “staffing its factories with migrants from Bangladesh, Nepal and other countries who went into crushing debt from paying exorbitant recruitment fees. Imports of bone charcoal from Brazil that firms like Plymouth Technology and ResinTech Inc. used to remove contaminants in U.S. water systems, diamonds from Zimbabwe and gold from eastern Democratic Republic of Congo, were stopped as well.”

According to Sarah Carpenter, manager of business and human rights at Assent Compliance and member of the Slavery and Trafficking Risk Template Development Committee,^[2] the writing has been on the wall for an enforcement action of this nature. Earlier this year, CBP readied the business community for engagement on forced labor at a trade symposium, including a specific panel on the issue, and ensured the enforcement of the forced labor provision within the Trade Facilitation and Trade Enforcement Act of 2015.^[3]