Skip content

Helping organizations respond effectively to U.S. WRO and lift import restrictions

When the U.S. Customs and Border Protection (CBP) issues a Withhold Release Order (WRO), businesses must provide clear, independent proof that forced labour indicators have been remediated.

LRQA delivers independent investigations, corrective action planning and verification to support organizations in meeting CBP requirements. Our experts combine on-the-ground experience and regulatory insight to identify root causes, design effective remediation programs and confirm compliance through credible reporting.

Our forced labour support services

Independent investigations

Our teams deliver in depth investigations to identify forced labor. Using the LRQA Forced Labor Investigations protocol which is aligned with 11 ILO Indicators of Forced Labour we provide a robust report that can be used to engage regulators, and engage key stakeholders.

Remediation and corrective action

Addressing forced labour requires more than identifying non-conformities. It requires fixing root causes.

We develop detailed, time-bound remediation plans tailored to your operations and suppliers. Our focus is practical implementation that delivers measurable change.

Capacity building and training

We provide targeted training and supplier engagement programmes covering: Responsible recruitment, recognising forced labour indicators, ethical labour management systems and ongoing risk identification and monitoring.

This strengthens internal capability and reduces the likelihood of future enforcement action.

Why work with us?

Global capability

With investigators and consultants worldwide, we combine local insight with global consistency. We understand regional labour risks and regulatory expectations across key sourcing markets.

Two people talking in a warehouse with large cable rolls in the background

Data Driven

EiQ’s self-managing ecosystem combines industry-leading data with decades of on-the-ground expertise. Every risk assessment sharpens predictions and strengthens your supply chain, advancing autonomous risk management

Group video call on a laptop

Regulatory credibility

We are a trusted partner to multinational brands, suppliers and legal advisers responding to WROs and forced labour allegations. Our methodology aligns with international standards and regulatory expectations

Warehouse worker in blue polo shirt inspecting a wrapped pallet among shelves and boxes.

Sustainable focus

Our work goes beyond compliance. We help organizations address systemic issues such as debt bondage and unethical recruitment practices, so that remediation leads to lasting change and improved human rights outcomes.

Frequently Asked Questions

What is a Withhold Release Order (WRO)?

A Withhold Release Order (WRO) is issued by the U.S. Customs and Border Protection (CBP) when there is reasonable evidence that goods have been produced using forced labour. When a WRO is in place, affected goods cannot enter the U.S. until the importer provides credible, independent evidence that forced labour indicators have been fully remediated.

LRQA supports businesses through independent investigations, corrective action programmes and follow-up verification to demonstrate compliance and regain market access.

How does the EU Forced Labour Regulation (EURLR) impact businesses?

The EU Forced Labour Regulation introduces powers to investigate and restrict products linked to forced labour within the EU market.

Companies will need to demonstrate robust due diligence, supply chain transparency and effective remediation where risks are identified. Independent assessment and verification are expected to play a significant role in demonstrating compliance.

Read our submission to the EU Forced Labour Regulation Call for evidence on the Guidelines on the implementation of the EU rules of forced labour. 

 

What are the 11 ILO indicators of forced labour?

The International Labor Organization (ILO) identifies 11 indicators of forced labour that help detect situations where individuals are coerced into work against their will. These indicators include: abuse of vulnerability, where workers are exploited due to poverty or lack of legal status; deception, involving false promises about work conditions; restriction of movement, preventing workers from leaving the workplace; isolation, cutting them off from contact with others; physical and sexual violence; intimidation and threats; retention of identity documents, such as passports; withholding wages, making workers financially dependent; debt bondage, where workers are trapped by inflated debts; abusive working and living conditions; and excessive overtime beyond legal or agreed limits. These indicators often occur in combination, signalling a high risk of forced labour.

Can LRQA support beyond regulatory investigation?

Yes. In addition to regulatory response, we support:

  • Supply chain risk mapping
  • Human rights due diligence
  • Responsible recruitment programmes
  • ESG and sustainability strategy integration
  • Supplier training and monitoring

Our services integrate with broader Responsible Sourcing programmes to strengthen long-term resilience.

What role does LRQA play in supplier remediation and training?

Beyond investigation and verification, LRQA supports with the development of corrective action plans that address root causes. This includes revising internal policies, improving living and working conditions and implementing grievance mechanisms.

We also deliver capacity building programmes, and industry initiatives equipping brands and suppliers with the tools and knowledge to sustain compliance with international labour standards.

Learn more about forced labour – view our online training courses

Get free access to our Recognising Forced Labor eLearning course on EiQ Learn. Use branch code WRO during registration. EiQ Learn is a comprehensive learning management system and eLearning course library designed specifically for supply chains. Our library includes hundreds of interactive, animated courses that help businesses understand risks, promote sustainable and compliant practices throughout the supply chain and remediate issues where they are found.

EiQ Learn: Use branch code WRO

Book your place today

Latest news, insights and upcoming events