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U.S. Customs & Border Protection (CBP) issued a forced labor finding on March 29, 2021 against Top Glove Corporation Bhd. (Top Glove), a Malaysian manufacturer of disposable gloves, a product which has been in high demand during the pandemic.  As a result, port directors may seize certain disposable gloves of Top Glove’s at U.S. ports of entry pursuant to section 307 of the Tariff Act of 1930 (19 U.S.C. 1307), which prohibits importation of merchandise mined, manufactured, or produced, in part or in whole, by convict, forced, or indentured labor.

A Withhold Release Order (WRO) was originally issued by CBP in July 2020 based on information that there were forced labor indicators within Top Glove’s production process, including “debt bondage, excessive overtime, abusive working and living conditions, and retention of identity documents.”  The company issued a press release on March 30, 2021 stating that they have worked with their consultants to improve Top Glove’s labor practices and are “working with CBP to quickly resolve the matter.”  In the meantime, U.S. importers should be aware that disposable gloves from Top Glove classified under the following Harmonized Tariff Schedule (HTS) subheadings are subject to seizure upon arrival:

  • 3926.20.1020
  • 4015.11.0150
  • 4015.19.0510
  • 4015.19.0550
  • 4015.19.1010
  • 4015.19.1050
  • 4015.19.5000

If any U.S. importers believe they may have disposable gloves from Top Glove in transit or scheduled for entry, then we encourage them to consult their trade or customs attorneys. Should you have any questions or concerns regarding this matter, please contact Robert Stang of Husch Blackwell’s International Trade and Supply Chain team.