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CBP Issues Two New Withhold Release Orders Against Jordanian Garment Manufacturers

CBP Issues Two New Withhold Release Orders Against Jordanian Garment Manufacturers

On June 23, 2026, U.S. Customs and Border Protection (CBP) issued two new Withhold Release Orders (WROs) against garments produced by Needle Craft Ltd. and Casual Wear Apparel L.L.C., two garment manufacturers located in Jordan. Effective immediately, CBP officers at all U.S. ports of entry will detain covered shipments after determining there is reasonable evidence indicating the use of forced labor in the production of the merchandise.

The actions represent the fifth and sixth WROs issued by CBP during Fiscal Year 2026, underscoring the agency’s continued commitment to enforcing U.S. laws prohibiting the importation of goods made with forced labor.

The Legal Authority Behind the WROs

The WROs were issued pursuant to Section 307 of the Tariff Act of 1930 (19 U.S.C. § 1307), which prohibits the importation of merchandise mined, produced, or manufactured wholly or in part with forced labor.

When CBP has information reasonably indicating that merchandise is produced using forced labor, the agency may issue a WRO directing ports nationwide to detain covered imports pending further review. Unlike a seizure, a WRO provides importers with an opportunity to demonstrate that the detained merchandise was not produced with forced labor or, alternatively, to export or destroy the goods.

With these latest actions, CBP now administers 58 active WROs and eight formal Findings under Section 307.

CBP’s Investigation

According to CBP, the WROs followed an extensive investigation into the labor practices at both Jordanian manufacturers. During its investigation, the agency reviewed a wide range of evidence, including:

  • Media reports;
  • Official Jordanian government documents;
  • Company statements;
  • Videos and photographs;
  • Worker and victim statements;
  • Public reports; and
  • Information provided by non-governmental organizations.

Based on this evidence, CBP concluded that there was reasonable suspicion that forced labor was being used in the production of garments manufactured by both companies.

Indicators of Forced Labor

CBP determined that workers at the two facilities were subject to seven International Labour Organization (ILO) indicators of forced labor, including:

  • Retention of identity documents;
  • Excessive overtime;
  • Intimidation and threats;
  • Physical and sexual violence;
  • Withholding of wages;
  • Restriction of movement; and
  • Abusive living and working conditions.

Taken together, CBP found that these indicators demonstrated workers were performing labor involuntarily under the menace of penalty, satisfying the standard necessary to issue a WRO.

What This Means for Importers

Importers sourcing garments from Jordan—or from suppliers with manufacturing operations in the region—should carefully evaluate whether their supply chains involve either of the affected manufacturers.

If merchandise is detained pursuant to these WROs, importers generally have three options:

  • Submit evidence demonstrating that the goods were not produced using forced labor;
  • Export the detained merchandise; or
  • Destroy the merchandise under CBP supervision.

Successfully overcoming a WRO detention often requires extensive documentation demonstrating supply chain traceability, labor compliance, and the origin of the imported merchandise.

A Continuing Expansion of Forced Labor Enforcement

These WROs continue a broader enforcement trend that extends beyond the Uyghur Forced Labor Prevention Act (UFLPA). While much attention has focused on imports connected to China’s Xinjiang Uyghur Autonomous Region, CBP continues to use its independent authority under Section 307 to target manufacturers located throughout the world when evidence indicates the use of forced labor.

Recent WROs involving manufacturers in Serbia and now Jordan demonstrate that forced labor enforcement is increasingly global in scope. Importers should not assume that sourcing outside traditionally high-risk jurisdictions eliminates forced labor compliance obligations.

Instead, companies should maintain comprehensive supplier due diligence programs, conduct ongoing supply chain risk assessments, and ensure they have documentation capable of supporting their compliance efforts if CBP initiates an enforcement action.

Looking Ahead

CBP’s latest WROs reinforce the agency’s commitment to aggressively enforcing U.S. forced labor laws across a broad range of industries and geographic regions. As investigations continue and additional WROs are issued, importers should expect increased scrutiny of labor practices throughout their global supply chains.

Businesses importing apparel or other labor-intensive products should regularly review supplier compliance programs, contractual obligations, and traceability procedures to ensure they are prepared to respond quickly if CBP detains a shipment.

Liang + Mooney PLLC assists importers with customs compliance, forced labor due diligence, UFLPA and Section 307 compliance, supply chain risk assessments, and responses to CBP detention, exclusion, and seizure actions. If your company has questions regarding forced labor compliance or is facing a CBP enforcement action, contact our team to schedule a consultation.

Disclaimer: This article is provided for informational purposes only and does not constitute legal advice; readers should consult qualified counsel regarding their specific circumstances.

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