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Forced-labor order

What is a Withhold Release Order (WRO)?

A Withhold Release Order (WRO) is an order CBP issues when it has information reasonably indicating that a class of goods is made with forced labor. It lets CBP detain those goods at the port. It is a separate mechanism from the UFLPA Entity List.

What a WRO does

When information gives CBP reasonable suspicion that merchandise is made wholly or in part with forced labor, CBP can issue a WRO. Port officers then detain shipments of that class of merchandise. A WRO stays in force until CBP revokes or modifies it — which can happen if an importer shows its supply chain is free of forced labor.

WRO vs the UFLPA Entity List

Both come from the same statute against forced-labor imports, but they work differently. A WRO targets a class of merchandise based on CBP's own findings. The UFLPA Entity List names specific companies and carries a rebuttable presumption. A supplier can be caught by one without appearing on the other, which is why a thorough check looks at both.

What an importer can do with detained goods

Importers of goods detained under a WRO can export or destroy the shipment, or try to show the goods are admissible. That last path is evidence-heavy supply-chain work, usually handled with specialist help.

Next step

Screen a Supplier checks a company against CBP's forced-labor orders and the UFLPA Entity List, plus federal sanctions lists, and shows the source and date behind each result.

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When this changes

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Related

  • CBP detained my shipment under the UFLPA — what it means
  • What is the UFLPA Entity List? (186 entities as of August 2026)
  • How do I screen a supplier for forced labor?
  • What is the UFLPA (Uyghur Forced Labor Prevention Act)?

Sources

  • CBP — Withhold Release Order and Finding Modifications Guide · read 2026-08-13
  • CBP — How does CBP enforce 19 U.S.C. 1307? (forced labor) · read 2026-08-13

Information current as of 2026-09-21.

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.

© 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.
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