WRO (Withhold Release Order)

A Withhold Release Order (WRO) is an enforcement instrument issued by U.S. Customs and Border Protection (CBP) under Section 307 of the Tariff Act of 1930 (19 U.S.C. § 1307), which prohibits the importation of goods mined, manufactured, or produced wholly or in part by convict labor, forced labor, or indentured labor, including forced child labor. When CBP has information "reasonably indicating" that imports fall within this prohibition, port directors are instructed to detain the shipments at the border.

Importers subject to a WRO have limited options: they may re-export the goods, or submit evidence within three months demonstrating that the merchandise was not produced with forced labor and a Certificate of Origin. If the evidence is insufficient, the goods are excluded or seized. A WRO can be elevated to a formal Finding, published in the Federal Register, which authorizes seizure rather than mere detention.

For decades Section 307 was rarely enforced because of a "consumptive demand" exception, repealed by the Trade Facilitation and Trade Enforcement Act of 2015. Since then, WROs have become a central tool in U.S. economic statecraft, particularly regarding supply chains linked to Xinjiang. Notable WROs have targeted cotton and tomato products from the Xinjiang Production and Construction Corps (issued December 2020), and various seafood, palm oil, and apparel producers. The Uyghur Forced Labor Prevention Act (UFLPA), signed December 2021 and effective June 2022, layered a rebuttable presumption on top of the WRO regime, shifting the burden of proof onto importers of goods with Xinjiang nexus.

WROs are significant in political-economy debates because they unilaterally extend U.S. labor standards extraterritorially, intersecting with WTO rules, corporate due-diligence regimes such as the EU Forced Labour Regulation (adopted 2024), and broader decoupling dynamics between Washington and Beijing.