U.S. Customs and Border Protection (CBP) issued two Withhold Release Orders against palm oil and its derivative products produced in Indonesia by Mitra Aneka Rezeki and Hardaya Inti Plantation, directing detention of that merchandise at all U.S. ports of entry. The orders reach any importer whose palm oil or palm-derived inputs trace to either producer. Importers of food, personal care, cleanings, and industrial products should confirm whether either company sits anywhere in their supply chain. 

KEY TAKEAWAYS 

  • CBP issued two Withhold Release Orders (WROs) covering palm oil and its derivative products produced in Indonesia by Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP). CBP stated that, effective immediately, personnel at all U.S. ports of entry will detain that merchandise. 
  • CBP cited nine International Labour Organization (ILO) forced labor indicators at MAR and seven at HIP. With this action, CBP stated it now oversees and enforces 60 WROs and eight Findings under 19 U.S.C. § 1307. 
  • Under 19 C.F.R. § 12.43, an importer contesting a WRO detention submits tailored certificates of origin from the foreign seller or owner and a detailed statement from the ultimate consignee within 3 months after the date the article was imported stating that no forced labor was used in making the product. DTL’s read: that record takes longer to build than the deadline allows if the work starts at detention. 

What CBP Announced

According to CBP’s national media release dated September 29, 2026, the agency issued two WROs covering palm oil and its derivative products produced in Indonesia by Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP). 

CBP stated that both WROs were issued due to violations of 19 U.S.C. § 1307, the statute prohibiting entry of goods made with forced labor. CBP also stated that its trade import data demonstrates the goods are being, or are likely to be, imported into the United States. 

CBP Office of Trade Executive Assistant Commissioner Susan S. Thomas stated: “Exploiting workers is inhumane and damaging to our economic and national security.” She added that the goods produced by these workers can put American businesses and consumers at risk. 

With this action, CBP stated it now oversees and enforces 60 WROs and eight Findings under 19 U.S.C. § 1307. 

What CBP Says It Found

CBP stated that both WROs resulted from a CBP review and that the agency analyzed interview transcripts, payroll slips, harvest quota information, photographs, open-source non-governmental organization and other government agency reports, news media, and academic research. CBP reported the following ILO indicators of forced labor for each producer. 

Source: CBP national media release, September 29, 2026. 

CBP stated that the facts underlying these indicators show, by reasonable suspicion, that workers are engaged in forced labor. That standard tracks 19 C.F.R. § 12.42(e), under which CBP directs port directors to withhold release when available information reasonably but not conclusively indicates that merchandise within the purview of section 307 is being, or is likely to be, imported. 

Where Palm Oil Exposure Hides in a Supply Chain

CBP’s release covers “palm oil and its derivative products” produced by MAR and HIP. The release does not list specific derivative products or tariff classifications. 

DTL’s read: the practical risk for many importers is not a direct purchase from MAR or HIP; it is palm oil or a palm-derived ingredient from these producers that passes through a mill, refinery, trader, or contract manufacturer before it reaches the importer of record. Palm oil supply chains commonly aggregate product from multiple sources, and an importer that has only mapped its direct vendor may not be able to say whether either producer is upstream. 

Palm oil is not new territory for CBP forced labor enforcement. In 2020, CBP issued WROs against palm oil produced by two Malaysian producers, FGV Holdings Berhad (September 2020) and Sime Darby Plantation Berhad (December 2020). In its December 2020 release, CBP noted U.S. Department of Agriculture reporting that palm oil is increasingly found in processed foods, cosmetics, pharmaceuticals, soap, and biodiesel. 

For more on how CBP has pursued forced labor enforcement outside China, see our coverage of the Jordan garment WROs and the Serbia copper WRO. 

What Happens When a Shipment Is Detained

CBP stated that importers of detained shipments may opt to destroy or export their shipments, or seek to demonstrate that the merchandise was not produced with forced labor. The regulations set the timeline for a WRO detention under 19 C.F.R. § 12.42(e). The rules differ for merchandise covered by a Finding under § 12.42(f), as the last row below shows. 

Source: 19 C.F.R. §§ 12.42 to 12.44, eCFR, current as of September 25, 2026.

As we reported in January, CBP’s Forced Labor Portal became the submission channel for WRO and Finding admissibility reviews effective January 21, 2026. 

DTL’s read: the certificate of origin under § 12.43(a) must come from the foreign seller or owner, and where the goods were produced in a country other than the country of export, the regulation calls for an additional certificate from the last owner or seller in that other country. For palm-derived ingredients refined or blended outside Indonesia, importers should expect to need cooperation from more than one party in the chain. 

Five Steps for Palm Oil Importers Now

The following are Diaz Trade Law’s recommendations, ranked by priority. 

  1. Screen every palm oil and palm-derived supplier against the new orders. Ask direct suppliers, refiners, and traders in writing whether they source from MAR or HIP, directly or through intermediaries, and document the responses. 
  2. Map palm inputs past the first tier. Identify the mills and plantations behind each palm-derived ingredient, not only the vendor on your commercial invoice. Where a supplier cannot identify its sources, treat that as a risk finding in its own right. 
  3. Pre-assemble the § 12.43 record. Line up the foreign seller or owner who would sign the certificate of origin, and build the ultimate consignee statement now: sourcing inquiries made, results received, and the basis for your conclusion on the labor used at each stage. 
  4. Update supplier contracts. Add forced labor prohibitions, upstream disclosure obligations, traceability recordkeeping, audit rights, and cooperation obligations for CBP admissibility submissions. 
  5. Build a detention playbook. Decide in advance who reviews a detention notice, who contacts the supplier, and what the decision criteria are for contesting, exporting, or destroying a shipment. Our Know Your Supply Chain: Forced Labor resource and our analysis of CBP’s Forced Labor Operational Guidance are a starting point. 

Positioning Your Supply Chain Ahead of the Next Order

DTL’s read: a WRO gives the importer no advance notice. The first sign is a detained shipment and a regulatory clock that runs from the date of importation. Importers that have already mapped palm inputs to the mill level, secured supplier cooperation commitments, and drafted their consignee statement are in a position to contest a detention on the record. Importers starting from a commercial invoice are more likely to face a choice between export and destruction. 

In our experience, the cost of a traceability exercise done before a detention is a fraction of the demurrage, storage, and lost-sale exposure of a detained shipment. That analysis applies to any commodity input with a history of CBP forced labor enforcement, and CBP has now issued palm oil WROs in both 2020 and 2026. 

How Diaz Trade Law Can Help 

Diaz Trade Law advises importers on forced labor due diligence, supply chain mapping, WRO detention responses, admissibility submissions through CBP’s Forced Labor Portal, and WRO modification requests. For assistance, contact Diaz Trade Law at info@diaztradelaw.com or 305-456-3830. 

Further Reading 

 

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