Turkmenistan Cotton Imports Banned in U.S.

Turkmenistan Cotton Imports Banned in U.S.

The U.S. Customs and Border Protection Agency (CBPA) has exercised its authority under the Tariff Act to issue a withhold release order (WRO) on all Turkmenistan cotton, or products produced in whole or in part with Turkmenistan cotton.

The WRO was issued on May 18, 2018, in response to systemic, state-orchestrated forced labor in Turkmenistan’s cotton sector. It formally bans these imports into the U.S.

According to the International Cotton Advisory Committee, Turkmenistan is the ninth largest producer and seventh largest exporter of cotton in the world. Its cotton is used in the supply chains of companies all over the world, including popular manufacturers and western apparel companies.

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This order is the latest in a series of WROs issued by the agency, including a ban on toys imported from a Chinese manufacturer. These highlight the ongoing success of the U.S. Trade Facilitation and Trade Enforcement Act in increasing the ability of the U.S. CBPA to prevent the import of products linked to forced labor.

What Does This Mean for You?

At first look, this WRO means companies need to quickly identify and eliminate Turkmenistan cotton from their supply chains. Failure to do so will lead to headaches at the border as products are held or turned away altogether.

However, waiting for WROs to be issued before taking action is an unsustainable approach to supply chain and product management. Actions such as these will continue to grow in number, forcing companies to scramble as they evaluate whether or not they are impacted.

Instead, taking a proactive approach to due diligence can help companies assess and mitigate supply chain risks, helping protect them against  CBPA actions on their operations.

Tools like the Slavery and Trafficking Risk Template (STRT) can be deployed across the supply chain, collecting data on risk that can then be actioned. It provides visibility into the policies, practices and procedures of suppliers, from Tier 1 through the rest of the chain. In the event that the CBPA does detain a company’s merchandise, they can demonstrate, with the help of STRT-collected data, that the merchandise was not made with forced labor.

Coupled with the Assent Compliance Platform, companies can leverage the STRT to start evaluating human trafficking and slavery risks in their supply chains. This will increase transparency and facilitate risk mitigation in advance of regulatory or legal actions, including new WROs issued by the CBPA. Do you know where your risks are? Contact us at info@assentcompliance.com to learn more.