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Title page

Contents

Highlights 2

Letter 6

Background 9

Forced Labor 9

Prohibition on Imports Produced with Forced Labor 10

Selected Federal Agencies' and Other Stakeholders' Efforts Related to Forced Labor 11

CBP Uses Several Tools to Enforce Section 307 14

WROs 14

Findings 16

Civil Penalties 17

CBP's Process for Issuing WROs and Findings 17

CBP's Process for Revoking and Modifying WROs 20

CBP Takes Steps to Communicate with Other Agencies and Stakeholders, but Its Process for Revoking WROs Lacks Transparency 22

CBP Takes Steps to Communicate about Forced Labor with Other Agencies and Nonfederal Stakeholders 22

CBP Plans to Publish Information about Its Process for Issuing WROS and Findings but Has Not Provided a Description of Its Process for Revoking and Modifying WROs 28

Federal Agencies and Nonfederal Stakeholders Generally Considered Section 307 an Effective Mechanism but Identified Related Challenges 34

Federal Agencies and Nonfederal Stakeholders Generally Viewed Section 307 as an Effective Enforcement Mechanism 34

Federal Agencies and Nonfederal Stakeholders Cited Several Challenges Related to Section 307 Enforcement 35

Conclusions 38

Recommendation for Executive Action 39

Agency Comments 39

Appendix I: Objectives, Scope, and Methodology 43

Appendix II: Indicators of Forced Labor Established by the International Labour Organization 46

Appendix III: U.S. Customs and Border Protection's Forced Labor Process Map 48

Appendix IV: Withhold Release Orders Issued by U.S. Customs and Border Protection, February 2016-January 2021 49

Appendix V: Working Groups Focused on Preventing the Import of Goods Produced with Forced Labor 52

Appendix VI: Selected Tools and Resources Identified by Federal Agencies and Nonfederal Stakeholders to Assist the Private Sector with Section 307 Compliance 55

Appendix VII: Comments from the Department of Homeland Security 61

Appendix VIII: Comments from USAID 64

Appendix IX: GAO Contact and Staff Acknowledgments 66

Tables

Table 1. Selected Federal Agencies' and Other Stakeholders' Efforts Related to Forced Labor 11

Table 2. Withhold Release Orders Issued by CBP, February 2016-January 2021 49

Figures

Figure 1. CBP Officials Inspecting Detained Goods Subject to Withhold Release Orders at U.S. Ports of Entry 14

Figure 2. CBP Process for Issuing Withhold Release Orders (WRO) and Findings 20

Figure 3. Forced Labor Indicators Identified by the International Labour Organization 47

Figure 4. CBP's Forced Labor Process Map 48

Figure 5. ILAB "Sweat & Toil" Mobile Application 56

Figure 6. ILAB "Comply Chain" Mobile Application 58

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