Build the labor due diligence evidence and supplier-level documentation that US Customs and Border Protection expects — before your shipment is detained.
For palm oil exporters, traders, and brands shipping to the US.
The enforcement
US Customs and Border Protection enforces Section 307 of the Tariff Act, which prohibits importation of goods produced wholly or in part with forced labor. Enforcement is via Withhold Release Orders (WROs) — shipments are detained at the port, and importers must prove the goods are forced-labor-free before release.
WRO issued — entire commodity category from a region or producer detained.
Detention at port — individual shipment held pending forced-labor review.
Burden of proof on importer — show evidence goods are forced-labor-free.
Why this matters now
WROs have been issued against major palm oil producers based on findings of forced labor indicators — including debt bondage, retention of identity documents, and abusive working conditions. The enforcement has been active and is unlikely to slow down.
From audit to evidence
Trace your supply chain to the mill, group, and concession — not just to the country of origin. CBP enforcement looks at producer-level evidence.
Powered by: Supplier Group Profiling · Ownership Mapping · Traceability to Mill Dataset
Documented evidence of labor due diligence — assessments of forced labor indicators, supplier audits, worker grievance records, and remediation tracking.
Powered by: Social Grievance Monitoring · Helpdesk Platform · Supplier Engagement
Field investigation records, worker interviews, and site verification reports — the kind of evidence CBP officers expect when reviewing detention release applications.
Powered by: Evidence & Field Investigation · Helpdesk Platform
If your shipment is detained, the time to build evidence is not the day of detention. Geometrack helps you build the response dossier in advance — structured, defensible, and ready to submit.
What teams miss
Traceability stops at country of origin, not mill or group.
Labor due diligence is policy statement, not documented program.
No field-verified evidence — only desk research and self-declared audits.
No pre-built response dossier, so detention becomes a crisis.
Bring your US-bound supplier list — we'll show you the evidence gaps and a path to a defensible detention response dossier.