CBP Issues Forced Labor Finding for Stevia Imports from a Chinese Manufacturer – Implications for U.S. Trade Compliance

Recommendation: offer robust due-diligence protocols, repeal vague regulatory expectations, and require independent third-party audits across production sites; establish chain-of-custody records and publish verification outcomes to inform American authorities and private partners, where available.

Recent data published by independent research teams highlights Detention events at select ports, with the number of detained consignments rising month over month. recently, morning briefings highlighted that risk levels vary by route, suggesting action where risk is higher and urging authorities to coordinate with port authorities to avoid unnecessary holds.

Efforts to map supply networks across cross-border corridors have spotlighted links between production chains and work-related constraints; the Asia-origin segment is believed to present greater risk than others, prompting enhanced third-party verification and економічний risk modelling. The states-mexico axis creates opportunities enabling private partners to avoid disruption, and those stakeholders are entitled to due process while regulators push for greater transparency, a stance believed by many policymakers that could increase oversight.

To minimize disruption, authorities should publish available data and facilitate private-sector readiness; use сторонніх виробників facilitation to verify supplier records; економічний analyses should compare production costs and enforcement outcomes across multiple governments. Recently published data and research support an increase in risk awareness; however, data refutes blanket claims that all cross-border activity carries the same risk, and the threat of penalties can resemble prison sentences should a firm fail to meet new standards. This approach does not aim to punish legitimate commerce.

Practical impact and action plan for importers under the finding

Immediate action: start a rapid due-diligence sweep of the supply base, focusing on custody of materials and derivatives; collect origin certificates, worker-rights attestations, and surveillance data; replace noncompliant sources. Maintain a live log of supplier statuses and red flags, available to senior management, and document decisions pursuant to security legislation.

Structure a private toolbox to guide decisions. Define reasonable risk criteria across origin, manufacturing places, and key materials. Require each supplier to demonstrate origin provenance, and to provide a master list of derivative inputs used in production. Adopt earlier published guidelines from kilgour, thirteen-point framework, and align with a unanimous industry standard; this approach can greatly reduce the menace of trafficking and related compliance threats.

Planning and governance: appoint Arnold as risk officer; implement a phased increase in supplier oversight; monitor xuar indicators; use mines risk mapping; ensure custody of materials and derivatives remains in-house when possible. Also require that admissible evidence is available; pursue custody steps; place emphasis on origin-based checks and private sector cooperation.

Entry controls and documentation: enforce robust entry controls accompanying shipments; require certificates, attestations, and traceability records; ensure all materials are accompanied by appropriate provisions; pursue a proactive approach to reduce vulnerabilities in the supply chain; adopt a diversified canadian option if feasible to reduce country risk; ensure all data is available to authorities; the table below outlines concrete steps.

Scope of the Finding: which stevia products and the implicated supplier are affected

Recommendation: establish an immediate map of product lines to the supplier named in the agencydocket, and suspend shipments of those lots until inspection confirms alignment between production records and released documentation.

The scope covers finished formats such as sachets, jars, and bulk powder, manufactured at the referred site during 2023 and 2024, with production lots named in the section of the docket. The results identify the item classifications associated with the instruction set and the documentation released to verify traceability.

The referred entity maintains assets in Turkmenistan and a china-linked operation in XUAR, with a brand line such as anasuya appearing in some records. This association raises responsibility questions across the supply chain, and journalists have highlighted allegations that officials will scrutinize, add provisions to the oversight framework, and require documentary evidence to corroborate claims.

Addition to due diligence includes establishing an auditable chain of custody for affected materials, completing an internal review, and aligning with provisions governing transparency. The inspection notes, documentation, and results will be evaluated to determine the sufficiency of the claims, while resource teams and journalists assess the context for convincing outcomes.

Next steps call for establishing a transparent remediation plan with a section-level update to republic authorities and cross-border regulators. Completion of corrective actions is expected within a defined timeline, with ongoing compliance monitoring and additional documentation requested as needed. Also, consider covid-19 related disruptions that may affect record-keeping, and ensure claims are supported by robust documentation produced through coordinated work with officials and associated partners.

CBP enforcement actions and timelines: detention, release options, and monitoring

Recommendation: implement a risk-based screening framework that triggers prompt release decisions when documentation demonstrates compliance, and codify this approach in section-specific guidance circulated to importers and brokers; align with parliament legislation and guidance from prior years to ensure legal clarity and predictable timelines.

Detention actions occur when suspected noncompliance emerges at entry, with a defined window to confirm facts; the enforcing authority may issue detention orders that halt release while verification proceeds, while production-related records support later decisions through cross-checks with producer sites.

Release options: If evidence shows mitigated risk, the agency may permit release under conditions, require additional documentation, or set a clear request to remedy gaps; release timelines are typically established by orders and can reference specific dates for response, while the underlying assessment remains open to reconsideration if new information arises after an initial decision.

Monitoring and timelines: Ongoing surveillance covers the sector through a risk-based approach, drawing on associated data and resource-sharing channels; covid-19-era disruptions shaped guidance and dates, while canada-united cooperation informs the cadence of checks; when goods enter the border, the process tracks entry, dates, suspected variances, and whether goods are wholly imported or rely on derivatives, to decide on clearance or targeted action; active monitoring helps identify evolving patterns, while those responsible for facilitation should keep records for years.

Compliance for importers and brokers: implement robust supplier verification, maintain production records and resource documentation, and submit requests for facilitation reviews when needed; ngos and journalists can contribute to oversight, applying independent checks after initial decisions; the canada-united framework provides a tested model for cross-border supervision, which can inform practice in other sectors; focus should be on ensuring transparency during December cycles and through ongoing monitoring; dates and orders should be publicly accessible to support substantial confidence in the process.

Supply chain due diligence: verifying Chinese suppliers and subcontractors

Recommendation: implement a formal, multi-layer due diligence framework that verifies every tier of the supply chain through documented data request, on-site validation, and continuous monitoring.

Develop an international vetting protocol that prioritizes risk indicators, requires real-time data about corporate structure, processing capabilities, and a verified roster of subcontractors, including operations in malaysia, and continue to refine criteria as new information becomes available.

Require formal documentation: registration details, official licenses, a line-by-line bill of materials, site-level audit reports, and a current list of contractors and sub-contractors. Verify through independent records and cross-check against official data sources to close gaps in information.

Establish a robust sub-tier management program that extends monitoring beyond first-tier suppliers, with periodic performance reviews and clear escalation routes when gaps are found.

Institute a formal plan to address enforcement risks, including custody and detention situations, with documented guidance on how to cooperate with authorities while protecting workers and ensuring timely orders to implement corrective actions.

Align with international governance norms by involving government officials and democratic institutions in risk assessments, and publish non-confidential guidance to increase transparency across markets and times.

Use independent audits or Kilgour-inspired assessments where feasible to corroborate management claims, ensuring each review produces concrete, trackable actions.

Maintain a secure information trail with controlled access, ensuring data retention supports continuous improvement while respecting privacy and regional laws.

Provide targeted training to suppliers and field staff, emphasizing ethical work practices, checklists for processing facilities, and practical steps to implement codes of conduct across the supply chain.

Track metrics such as audit completion rates, remediation timelines, and the number of verified subcontractors, using a broad dashboard to support ongoing risk reduction and continuous improvement in international operations.

Address risks such as trafficking in supply chains by applying international guidance where government officials and democratic authorities share information; request timely updates, maintain custody logs, and increase transparency to support better decision making and risk mitigation across the global network.

Remediation strategies: how importers can adjust sourcing and mitigate risk

Diversify supplier base by qualifying two new regional partners and reallocating 20–30% of inputs to lower-risk options within 60 days.

Pursuant to internal policy, establish an accountable procurement governance within the administration with a clear set of obligations and escalation paths, plus an autonomous oversight function.

Develop a toolbox of risk controls, including due-diligence checklists, on-site verifications, worker interviews conducted by independent teams, and document reviews; use investigations when anomalies appear to verify program integrity.

Institute end-to-end traceability of inputs, leveraging digital records and a supplier portal to capture country-of-origin data, batch details, and change history across international networks. Provided data from pilots demonstrate improvements across times: initial baseline, mid-cycle, and ongoing.

Set priorities and metrics: number of suppliers covered, frequency of checks, and remediation actions tracked with a quarterly summary; organize the plan with headings and part-by-part milestones and document progress times.

Strengthen contracts to increase obligations and tie payments to verified improvements, with explicit timeframes and penalties tied to non-conformance across suppliers in the network.

Operational continuity: if a partner leaves the program, volumes are reallocated to compliant sources to maintain flow, supported by a formal exit plan and rapid onboarding of alternates.

Summary: this approach accelerates risk reduction, supports both businesses and administrations, and yields measurable results within a 6–12 month horizon. Details include the onboarding timeline, investigations cadence, inputs validation, and procurement controls applied across country footprints, with the number of steps and responsibilities clearly defined.

Documentation and recordkeeping: required data, certifications, and audit readiness

Adopt a centralized, auditable documentation framework that applies across all suppliers, with mandatory data fields, verifiable certifications, and an ongoing audit readiness program. Maintain a domestic, secure repository with version control, access logs, and a clear procedure to handle updates without compromising prior records. Establish a background section that ties data elements to the regulator’s authority and public expectations, and map them to the agencydocket record.

• Entity identifiers: supplier name, legal form, physical address, and country of establishment.
• Background and country: documented history, corporate structure, and country of origin where operations occur.
• Product data: description, sector classification, commodity code (HS/HTS), and a pspc code when applicable.
• Traceability: batch/lot numbers, production dates, and shipment dates, with a clear linkage to downstream users.
• Documentation of certifications: certificates of origin, supplier attestations, and any third-party audit reports.
• Labor and responsibility attestations: worker rights statements, safety compliance proof, and fair-treatment notices.
• Audit artifacts: internal and external findings, corrective action plans, remediation evidence, and status updates.
• Public claims and settlements: records of public statements, settlements, or agreements, with dates and outcomes.
• Enforcement posture: agencydocket numbers (if any), penalties, prohibitions, or settlements, with effective dates.
• Recordkeeping controls: access controls, version history, disaster recovery plans, and the ability to restore archived data.
• Data integrity: hash-based verification, immutable storage, and regular integrity checks to prevent tampering.
• Cross-border indicators: documentation for the states-mexico corridor and any supplier locations in that region.

1. Certification program governance: establish executive sponsorship, with a documented policy approved by executive leadership and aligned to a defined section of the regulatory framework.
2. Verification cadence: require annual, and when needed ad hoc, verification of certificates, attestations, and audit reports; ensure procedures allow removal or replacement of records that are outdated or superseded, with justification.
3. Public reporting and disclosure: implement a transparent approach to reporting on verification outcomes while protecting sensitive information; maintain a clear path to public accountability without exposing sensitive data.
4. Auditor readiness playbook: compile a ready-to-activate set of documents, including a summary of control owners, escalation paths, and contact details for the authority’s questions; include step-by-step guidance for responding to agencydocket inquiries.
5. Penalties and settlements: document potential penalties, prohibitions, and settlement options, with contingency plans to address identified gaps and to avoid escalation.

Operational guidance: apply a risk-based approach to coverage, prioritizing sectors with pressing due diligence needs. Earlier feedback from advocates and industry advisers provides a framework to strengthen domestic controls, minimize gaps, and support full traceability across the supply chain. If a supplier is removed from the roster, the system must retain a full justification and the historical record remains accessible for auditability, without compromising ongoing operations.

Implementation timeline and risk management: establish a march-wide rollout plan with concrete milestones spanning years of activity; continuously improve the data model, reporting templates, and audit trails. If gaps persist, authorities may issue public notices, require additional reporting, or pursue a formal enforcement action; maintaining a robust background is essential to address claims and to uphold public trust across the sector.

Advisor notes: the framework provides practical advice to strengthen the domestic program, while allowing stakeholders to continue normal operations. The structure supports authorities, advocates, and business units by delivering comprehensive, fully auditable records that stand up to scrutiny in the event of an inquiry or settlement negotiation.