CBP seizes 4.6 million disposable gloves due to forced labor finding.


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According to a U.S. Customs and Border Protection (CBP) media release, officers in Missouri seized over 4.68 million latex gloves from a subsidiary of Malaysia based Top Glove Corporation Bhd. The seizure valued at $690,000 was due to information provided to CBP the gloves were manufactured using forced labor – a form of modern slavery.

Specifically, CBP issued a forced labor finding – in which they suspect Top Glove’s production process to include debt bondage, excessive overtime, abusive working conditions, abusive living conditions and the retention of identity documents.

Unfortunately for Top Glove, CBP will continue seizing their goods until Top Glove can prove future glove shipments were not produced using forced labor. In general, forced labor also includes indentured labor, use of convict labor, and child labor.

CBP issued a forced labor finding on March 29 based on evidence of multiple forced labor indicators in Top Glove’s production process, including debt bondage, excessive overtime, abusive working and living conditions, and retention of identity documents.

If your company is suspected of using forced labor. contact David Hsu anytime by phone/text at 832-896-6288 or by email at attorney.dave@yahoo.com. Forced labor compliance is the new, hot enforcement area for Customs and Border Protection.

If you are an importer, and are concerned about forced labor accusations, contact us also to create your forced labor compliance program.

CBP revokes WRO on tuna harvested by the Tunago 61 vessel.

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According to a U.S. Customs and Border Protection media release – CBP announced that tuna and tuna products harvested from the Tunago No.61 vessel will be admissible at all U.S. ports of entry beginning April 1, 2020.

The revocation of withhold release order (WRO) on tuna and tuna products harvested from the Tunago No. 61 vessel was based on information provided to CBP that tuna and tuna products from this vessel are no longer produced under forced labor conditions.

A WRO is put in place prohibiting the importation of certain goods if CBP believes the goods being imported were made wholly or in part by forced labor, including convict labor, forced child labor, and indentured labor.

If you are subject to a pending WRO and want to discuss your options, or if you are aware of an importer using any type of forced labor; contact experienced customs attorney David Hsu by phone/text at 832-896-6288 or by email at attorney.dave@yahoo.com.

Children in China forced to produce Amazon Alexa devices. Where’s the outrage?

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According to the Guardian, a leaked document by China Labor Watch details school children in China forced to work over night to produce Amazon Alexa devices. The children were required to work nights and overtime to produce the smart-speaker devices at Foxconn, an OEM manufacturer supplying Amazon’s Alexa-enabled devices.

The documents delivered to the Guardian indicate teenagers from schools and technical colleges in China were classified as “interns” with teachers being paid by the factory to accompany the students. The legal age of employment is 16, but school children are not allowed to work at night or overtime.

One “intern” quoted in the report said they were applying protective film on 3,000 Echo dots a day for 10 hours a day, six days a week for $2.34 an hour. When the intern complained, their teacher told them they had to work or else it may impact their ability to graduate from school.

Foxconn admitted students were working and they vowed to take action to remedy the problem. As Foxconn is also the OEM for Apple’s iPhone, it is unknown whether school children also made those devices.

It will be interesting to see what penalty Amazon will face. Most likely there will be a disparity in punishment – for example, the Ivory Coast is facing a potential ban of cocoa to the US due to the use of child labor; but there is no discussion for a ban of Amazon Alexa products. tudying computing, was given the task of applying a protective film to about 3,000 Echo Dots each day. Speaking to a researcher, she said she was initially told by her teacher that she would be working eight hours a day, five days a week, but that had since changed to 10 hours a day (including two hours’ overtime) for six days a week.

Will post more Amazon child labor violations as soon as they become available.

U.S. may ban cocoa imports from Ivory Coast due to potential use of child labor.

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Last week, Ivory Coast’s First Lady and US officials met to discuss a proposed US ban on Ivory Coast cocoa. Ivory coast is the world’s largest supplier of cooca (supplying 1/3 of all the world’s cocoa supply) and the Ivory Coast government is fighting every effort to block Ivorian cocoa from entering US ports.

The use of forced child labor to harvest cocoa has been an issue many chocolate wholesalers such as Mars, Nestle and Hershey have tried to eliminate, mostly through efforts such as monitoring supply chains and certification by third-party monitors. However, the recent report by two US Senators includes evidence of continued use of forced labor and the Washington Post reported earlier in June that 2 million children work in West African cocoa farms.

The Senators believe a new ban would further increase pressure on cocoa farmers and Customs officials are authorized to ban all products from entering the US if evidence indicates the products are or reasonably indicate they are produced with forced or indentured labor.

Will post more if the ban goes through, and if you want to avoid your company facing a ban due to any future customs issues, contact experienced trade and compliance attorney David Hsu, we can audit the supply chain process prior to importation to ensure compliance, call 832-896-6288 or by email at attorney.dave@yahoo.com, dh@gjatradelaw.com.