U.S. Exposure to Forced Labor Exports from China Developments since the U.S. Trade Facilitation and Trade Enforcement Act of 2015

Four New WROs Issued against Chinese Companies since the Repeal of the Consumptive Demand Exemption Since the repeal of the consumptive demand exemption entered into force, CBP has issued four WROs against Chinese companies that remain active currently—the first WROs to target Chinese companies since 1996. CBP told the Commission that CBP received the allegations behind all four cases before the signing of the TFTEA and issued the relevant WROs after its signing. Elizabeth G. Kurpis, associate at the law firm Mintz Levin, argued that the food and apparel industries are most likely to be affected by the TFTEA since those two industries tend to have supply chains that are most compromised by forced labor. Indicating the TFTEA is already having an effect, Ms. Kurpis pointed out that Tangshan Sanyou Group—one of the Chinese companies targeted by a WRO since the TFTEA entered into force—appears to have been “permanently closed.” CNN also reported that Tangshan Sanyou Group and Tangshan Sunfar Silicon Company, another company targeted by a WRO, appeared to be closed, as calls to their listed numbers went unanswered or the lines were disconnected. Commission staff also were unable to reach either company by phone numbers listed online, which appeared to be disconnected, suggesting the companies may no longer be in operation.

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