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.
Is your supplier on a forced-labor or sanctions list? Type the registered name and check it — free.
| Withhold Release Order (WRO) | UFLPA Entity List | |
|---|---|---|
| What it covers | A class of goods, often from a named producer | Named companies |
| What it rests on | CBP's reasonable suspicion of forced labor | A listing kept by DHS's forced-labor task force |
| What happens at the port | Shipments are detained | Goods are presumed barred from entry |
| What the importer can do | Export 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
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.
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.
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.
Is your supplier on a forced-labor or sanctions list? Type the registered name and check it — free.
Check a supplier — free →Checking the supplier is the first step of the plan for your product. The plan lists the rest in order, with a source for each line. It's free, with no signup.
See the plan for your product →The rules on this page do change — an eFiling date, a list, a threshold. Leave an email and a short note goes out if one does: a few a year at most, one click to stop, and the address is used for nothing else. A summary of the guide and a link arrive now, as confirmation.
Information current as of 2026-10-20.
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.
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.