U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against imports made in Mauritius by manufacturer Firemount Group Ltd. (Firemount) after an investigation indicated forced labor use. This WRO was the fourth issued in 2025. CBP now oversees and enforces 54 WROs and nine Findings.
What Happened
On November 18, 2025, CBP issued the WRO against garments, apparel, and textiles manufactured in Mauritius by Firemount. CBP will immediately detain imports subject to the Order. The WRO was issued based on information that reasonably indicates forced labor was used in violation of 19 U.S.C. §1307.
In making this determination, CBP conducted an investigation and analyzed supporting evidence, including interview questionnaires, audio recordings and transcripts, open-source reports from nongovernmental organizations, news media, and academic research.
The evidence demonstrated that Firemount workers are subject to four International Labour Organization indicators of forced labor: abuse of vulnerability, debt bondage, deception, intimidation, and threats.
WRO Background
The strategic use of WROs by CBP has been especially effective at identifying certain nations, industries, and companies that employ forced labor. CBP issues WROs after receiving information that reasonably indicates the use of prison or forced labor at any point in an imported product’s supply chain. Before the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), the United States had only implemented 30 WROs in the previous five decades. Since 2016, however, the agency has now overseen more than 50 active WROs.
CBP provides the public with a list of all WROs and the conclusions of their forced labor investigations.
CBP carries out a number of steps prior to issuing a WRO and detaining merchandise if it is linked to forced labor.
Below is a chart categorizing CBP’s detention process for merchandise-related forced labor:
What Importers Should Do to Address Forced Labor
CBP published a forced labor Reasonable Care Checklist that includes 12 questions importers must be able to answer in order to demonstrate they have used reasonable care. Key to this checklist is knowing “how your goods are made, from raw materials to finished goods, by whom, where, and under what labor conditions.” Understanding who is supplying you with a product is not enough; you also need to know who is supplying them.
At a minimum, you should maintain the following information:
- Detailed description of your supply chain, including all stages of production
- A list of suppliers involved in each step of the production process
- Contact information for all suppliers
- Documentation that can be used to trace raw materials to merchandise
- Manufacturing or production records
- Reports on factory conditions, including reports on site visits
- Reports showing that the volume of inputs matches the volume of outputs for merchandise produced
The documentation process can also help you defend your reasonable care duty down the road should you face a CBP enforcement action. Importers should also write standards into their contracts, set up screening for partners, utilize technology, and conduct regular audits.
Read more about the steps importers can take to understand and protect their supply chains here.
How to Modify a WRO
WROs and Findings can be modified. On June 2, 2025, CBP issued a comprehensive WRO and Finding Modification Guide that provides a roadmap for importers facing allegations of forced labor. The guide outlines a “Identify, Correct, and Prevent” framework to remediate forced labor claims.
Identify: An entity subject to a WRO or Finding should conduct a comprehensive review of its supply chains to identify forced labor risks.
Correct: Entities should develop a “Corrective Action Plan” to address forced labor issues and prevent additional issues in the future.
Prevent: Entities should address the causes of forced labor and implement remedies, including strengthening internal controls and ensuring workers can easily report violations.
The guide makes clear that the bar is high to prove that an importer has taken the proper steps to warrant a modification. However, it has happened; for example, in 2023, CBP modified a WRO against a group of companies known collectively as Smart Glove in response to the companies’ remedial efforts, which included payment of back wages.
Forced labor remains a priority for CBP. Importers should seek counsel for assistance with audits and compliance. For assistance with due diligence, re-exporting your detained merchandise, submitting documents to dispute the use of forced labor, or for assistance with the revocation request process, contact Diaz Trade Law at info@diaztradelaw.com or 305-456-3830.
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