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ARTICLE · 26 JUNE 2025

CBP Issues First Comprehensive Guide To Modifying A Withhold Release Order (WRO)

Crowell & Moring LLP
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Guidance from CBP to modify WROs represents a key barometer for compliance programs for importers to institute preemptively, since importers are strictly liable for their supply chains.

United StatesInternational Law
David R. Stepp
David R. Stepp
Sibilla Grenon
Sibilla Grenon
Pierfilippo M. Natta
Pierfilippo M. Natta
Simeon Yerokun
Simeon Yerokun
Andrew Schlegel
Andrew Schlegel

What You Need to Know

Key takeaway #1

Guidance from CBP to modify WROs represents a key barometer for compliance programs for importers to institute preemptively, since importers are strictly liable for their supply chains.

Key takeaway #2

CBP introduces an "Identify, Correct and Prevent" framework which involves identifying risks, implementing corrective actions, and establishing preventative measures to ensure compliance and ethical labor practices.

Key takeaway #3

CBP emphasizes remedies focused on worker concerns, thereby requiring interaction with workers, establishing robust grievance mechanisms, and engaging with worker representatives to ensure all voices are heard.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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