Supply chains in focus: CBP forced labor enforcement continues

United States Customs and Border Protection (CBP) recently issued its fourth Withhold Release Order (WRO) of 2025 to detain garments, apparel, and textiles manufactured in Mauritius by Firemount Group Ltd.

Based on information that reasonably indicates the use of forced labor to produce the goods in violation of Title 19 of the US Code, Section 1307, the WRO was issued on November 18, 2025. This WRO followed 53 others and nine findings CBP has administered pursuant to Section 1307. 

The agency continues to prioritize forced labor enforcement across global supply chains, reinforcing the need for companies importing products into the US to conduct appropriate assessments, monitor their supply chain partners, and broaden their jurisdictional focus for forced labor. 

The WRO announcement follows extensive civil society scrutiny of labor conditions in Mauritius. Between 2023 and 2024, the nongovernmental organization (NGO) Transparentem investigated allegations of forced labor at Firemount and several other garment manufacturers in Mauritius, which prompted international buyers that sourced from the named factories to pay compensation to workers and take other remedial measures. 

While it is not clear whether CBP’s action was directly prompted by Transparentem’s reporting, the investigation likely contributed to heightened scrutiny by CBP and other government agencies. In support of the WRO, CBP cited evidence including worker interviews, audio recordings and transcripts, and open-source reports demonstrating four International Labour Organization indicators of forced labor at Firemount’s facilities: abuse of vulnerability, debt bondage, deception, and intimidation and threats.[1] 

This action also underscores an important nuance in apparel sourcing. Unlike the focus on lower-cost, fast-fashion companies that are more often cited for forced labor, Firemount is known for manufacturing high-quality “upmarket” denim. The WRO emphasizes that forced labor risk assessments should look beyond broad product categories to the specific labor practices of individual manufacturers and facilities – even those producing premium goods. Compliance leaders are encouraged to calibrate diligence and monitoring to reflect the realities of tiered supply chains, subcontracting, and labor recruitment practices at the factory level. 

CBP continues to receive allegations from government agencies, media, NGOs, and members of the public, including via CBP’s Forced Labor Allegation Portal. The portal enables any person to submit detailed forced labor allegations that can amplify reporting from activist groups and NGOs, increasing enforcement risk for companies across the apparel sector and beyond. 

As such, heightened forced labor enforcement at the US border, including the issuance of more WROs, can be expected. Indeed, CBP recently added a benefit to the Customs Trade Partnership Against Terrorism Trade Compliance program (CTPAT) that will give members advance notice (up to 48 hours) from the agency before issuing a WRO.[2]

_{[1] CBP issues Withhold Release Order on Firemount Group Ltd., U.S. Customs and Border Protection, November, 18, 2025. Available at: https://www.cbp.gov/newsroom/national-media-release/cbp-issues-withhold-release-order-firemount-group-ltd, last accessed December, 3, 2025.} 

_{[2] https://www.cbp.gov/sites/default/files/202511/ctpat_forced_labor_requirements_faqs_updated_november_2025_approved_508.pdf}