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U.S. Customs and Border Protection Issues Withhold Release Orders on Imports from Two Jordanian Garment Manufacturers

July 2, 2026

On June 23, 2026, U.S. Customs and Border Protection (“Customs”) issued two Withhold Release Orders (“WROs”) against garments produced by Needle Craft Ltd. and Casual Wear Apparel LLC in Jordan. The WROs, issued pursuant to 19 U.S.C. § 1307, authorize Customs to detain covered merchandise entering the United States based on reasonable suspicion that it was produced using forced labor.

Background

Eliminating forced labor throughout global supply chains has become a top priority for Customs, as seen by the recent Section 301 investigations and through enforcement actions such as these WROs. WROs serve as a sifter to stop products presumed to be made with forced labor from entering the U.S. market. When Customs imposes a WRO it denies access to one of the world’s top consumer markets for products suspected of having forced labor violations. Maintaining access to the U.S. consumer market is a strong incentive for many businesses; the WRO system uses this incentive as leverage to discourage forced labor globally.

Customs conducts thorough investigations before implementing this ridged tool, although the standard of proof for a WRO to be implemented is relatively low—only reasonable suspicion is required. The most recent investigation into the two garment production factories was made with great scrutiny and examination. The Customs investigation included media reports, official Jordanian government documents, company statements, videos, photographs, victim statements, public reports, and statements from nongovernmental organizations.

Based on that investigation, Customs found reasonable suspicion that workers at both facilities were subjected to seven International Labour Organization (“ILO”) indicators of forced labor:

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

Customs also determined that garments produced by the two manufacturers are being, or are likely to be, imported into the United States.

Implications for Importers

Customs will detain covered shipments imported from these manufacturers. Importers whose merchandise is detained generally may:

  • Export the merchandise
  • Destroy the merchandise under Customs supervision
  • Seek to demonstrate that the merchandise was not produced with forced labor

Importers seeking release of detained shipments should be prepared to provide documentation sufficient to establish that the merchandise is admissible under Section 1307.

Seeking release of detained shipments requires detailed supply chain documentation and accurate recordkeeping. Global companies should review their traceability procedures to mitigate detention risk. Similarly, U.S. importers should regularly conduct supply chain due diligence to ensure that their supply chains are demonstrably free from forced labor.

Continued Forced Labor Enforcement

These actions constitute Customs fifth and sixth WROs issued during Fiscal Year 2026. Customs now administers 58 active WROs and eight Findings under Section 1307.

The WROs illustrate Customs continued use of company-specific enforcement actions where the agency determines there is reasonable suspicion that forced labor was used in production.

Key Takeaways

  • Customs continues to prioritize enforcement of U.S. trade laws.
  • Customs has issued WROs covering garments produced by Needle Craft Ltd. and Casual Wear Apparel LLC in Jordan.
  • Merchandise covered by the WROs will be detained upon importation unless the importer establishes that it is admissible.
Contact the Clark Hill International Trade practice if you have additional questions about forced labor compliance, supply chain due diligence, and traceability procedures.

This publication is intended for general informational purposes only and does not constitute legal advice or a solicitation to provide legal services. The information in this publication is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this information without seeking professional legal counsel. The views and opinions expressed herein represent those of the individual author(s) only and are not necessarily the views of Clark Hill PLC or Clark Hill Solicitors LLP. Although we attempt to ensure that postings on our website are complete, accurate, and up to date, we assume no responsibility for their completeness, accuracy, or timeliness.

 

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