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Forced-labor order
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What is a Withhold Release Order (WRO)?

In one line

In shipping, WRO stands for Withhold Release Order. CBP issues one when it has reasonable suspicion that goods are made with forced labor, and port officers then detain shipments of those goods. It's a separate tool from the UFLPA Entity List.

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WRO or UFLPA Entity List: what's the difference?
Withhold Release Order (WRO)UFLPA Entity List
What it coversA class of goods, often from a named producerNamed companies
What it rests onCBP's reasonable suspicion of forced laborA listing kept by DHS's forced-labor task force
What happens at the portShipments are detainedGoods are presumed barred from entry
What the importer can doExport or destroy the goods, or send proof (due within 3 months of import)Show there's no tie, or rebut with clear and convincing evidence

A Finding is a stronger order than a WRO: goods under it can't be exported.

Source: 19 CFR 12.42–12.44; CBP, Forced Labor Enforcement Operational Guidance for Importers (June 2026); Public Law 117-78

What does a WRO do?

It tells port staff to detain shipments of the goods it covers: a class of goods, often from a named producer. CBP issues it when information reasonably, but not conclusively, shows that forced-labor goods are being imported or are likely to be.

A WRO stays in force until CBP revokes or changes it. The company it names can ask for a change by showing it has fixed all forced-labor conditions.

How is a WRO different from the UFLPA Entity List?

Both enforce the same U.S. ban on goods made with forced labor, but they work differently. A WRO targets a class of goods on CBP's reasonable suspicion. The UFLPA Entity List names companies, and their goods are presumed barred unless the importer proves otherwise. A supplier can be caught by one and not the other, so a thorough check looks at both.

What can you do with goods held under a WRO?

Export them, destroy them, or ask CBP to review proof that they weren't made with forced labor. The proof is due within three months of the import date. Say the goods were imported on May 1: the three months run to August 1.

A Finding is different. It's a stronger order, issued on probable cause, and goods under a Finding can't be exported. Unless the importer shows they weren't made with forced labor, they're seized and forfeited. The review is evidence-heavy supply-chain work, usually done with specialist help.

Next step

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Related

  • CBP detained my shipment under the UFLPA — what it means
  • How do I respond to a customs detention notice from CBP?
  • UFLPA Entity List: 190 entities after the October 29, 2026 update
  • How do I screen a supplier for forced labor?
  • What is the UFLPA (Uyghur Forced Labor Prevention Act)?

Sources

  • CBP — Forced Labor Enforcement Operational Guidance for Importers (June 2026: a WRO directs port personnel to detain the goods; reasonable suspicion; three months to export, destroy or request an admissibility review; goods under a Finding can't be exported) · read 2026-10-20
  • CBP — Withhold Release Order and Finding Modifications Guide (a WRO stays in force until revoked or modified; petitions show all forced-labor conditions remediated) · read 2026-10-20
  • CBP — How does CBP enforce 19 U.S.C. 1307? (forced labor; a Finding means seizure and forfeiture, no export) · read 2026-10-20
  • eCFR — 19 CFR 12.42–12.44, Forced labor (current text, read via the eCFR versioner): 12.42(e) "reasonably but not conclusively indicates"; 12.43(a) proof within 3 months after the date imported; 12.44 export, seizure · read 2026-10-20

Information current as of 2026-10-20.

Legal Disclaimer+

This report is an automated, informational screening tool only. Tiana & Co. is not a licensed customs broker and does not conduct customs business. This report does not constitute legal advice, a compliance determination, or a certification of admissibility for any supplier, product, or shipment.

Verdicts in this report are produced by deterministic code, not by a language model. The explanatory paragraph accompanying each check is model-generated and checked against the cited sources before delivery. No part of this report is reviewed by a person before it is issued, so every material finding and citation should be confirmed against the underlying government source before it is relied on.

This report reflects data available as of the report date. The OFAC SDN and Consolidated lists, the other U.S. Consolidated Screening List constituents, the UFLPA Entity List, CBP withhold release orders, CPSC's eFiling list, and regulatory guidance are updated frequently and without prior notice. Users should re-screen periodically and consult qualified counsel for compliance decisions.

Name-similarity results do not establish or rule out the identity of any company. Where multiple similarly named records exist, none should be treated as confirmed without independent verification against the primary government source.

This tool is not affiliated with, endorsed by, or a substitute for U.S. Customs and Border Protection, the U.S. Department of the Treasury, the Consumer Product Safety Commission, or any other government agency. No warranty is made as to the accuracy, completeness, or currency of any finding.

Use of this report for import, procurement, sanctions-compliance, or investment decisions is at the user's own risk. Anyone with compliance obligations under UFLPA, OFAC, or CPSC regulations should consult qualified legal counsel before making a transactional decision.

Legal Disclaimer

This report is an automated, informational screening tool only. Tiana & Co. is not a licensed customs broker and does not conduct customs business. This report does not constitute legal advice, a compliance determination, or a certification of admissibility for any supplier, product, or shipment.

Verdicts in this report are produced by deterministic code, not by a language model. The explanatory paragraph accompanying each check is model-generated and checked against the cited sources before delivery. No part of this report is reviewed by a person before it is issued, so every material finding and citation should be confirmed against the underlying government source before it is relied on.

This report reflects data available as of the report date. The OFAC SDN and Consolidated lists, the other U.S. Consolidated Screening List constituents, the UFLPA Entity List, CBP withhold release orders, CPSC's eFiling list, and regulatory guidance are updated frequently and without prior notice. Users should re-screen periodically and consult qualified counsel for compliance decisions.

Name-similarity results do not establish or rule out the identity of any company. Where multiple similarly named records exist, none should be treated as confirmed without independent verification against the primary government source.

This tool is not affiliated with, endorsed by, or a substitute for U.S. Customs and Border Protection, the U.S. Department of the Treasury, the Consumer Product Safety Commission, or any other government agency. No warranty is made as to the accuracy, completeness, or currency of any finding.

Use of this report for import, procurement, sanctions-compliance, or investment decisions is at the user's own risk. Anyone with compliance obligations under UFLPA, OFAC, or CPSC regulations should consult qualified legal counsel before making a transactional decision.

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© 2026 Tiana & Co. LLC · Import Intelligence for small importers · Not a licensed customs broker. Not legal advice. Sources and retrieval dates are shown with each result.