Forced labor modification for Top Glove Corp. Bhd.

a woman with gloves
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Back in March of 2021, CBP published a finding of forced labor in the Federal Register for disposable gloves produced in Malaysia by Top Glove Corporation Bhd. The finding against Top Glove was due to reports of forced labor indicators such as: debt bondage, excessive overtime, abusive working and living conditions and retention of identity documents.

A finding of forced labor results in a “Withhold Release Order” (WRO) that instructs CBP to seize shipments of the gloves produced using the forced labor. It is then up to the importer to prove the merchandise was not produced with forced labor.

The process a company needs to take involves a request to modify or revoke a finding. Each situation is different, but in general, CBP will modify a WRO or findings if there is enough evidence the subject merchandise is no longer produced or manufactured using forced labor.

In Top Glove’s situation – Top Glove paid $30 million in payments to workers and improved the living and working conditions at the company’s facilities.

If you are subject to a WRO or CBP finding of forced labor, or if you have any compliance concerns to ensure your company is not subject to a WRO or finding of forced labor, contact David Hsu by phone/text anytime at 832-896-6288 or by email at attorney.dave@yahoo.com.

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


crop unrecognizable person in rubber gloves raising arms
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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.