CBP Withhold Release Orders Two Target Indonesian Palm Oil Producers

Background

U.S. Customs and Border Protection (CBP) has issued Withhold Release Orders (WROs) against Indonesian producers of palm oil, Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP), based on forced labor indicators. Under 19 U.S.C. § 1307, CBP may detain palm oil and palm-derived products produced wholly or in part by either company. As a result, importers must then destroy, export the goods or provide evidence sufficient to establish admissibility.

Why This Matters

The WROs will impact any company importing palm oil, palm-derived ingredients, or finished goods containing them—including food, cosmetics, personal care, household, pharmaceutical, and consumer products. Exposure to these WROs may result from suppliers that are several tiers upstream through refiners, traders, processors, and ingredient suppliers. In addition, palm derivatives may appear under technical names. Knowing the finished-goods manufacturer or direct supplier may therefore be insufficient if an importer cannot trace the underlying palm source.

Key Takeaways

• Map exposure. Identify imported products and ingredients that contain palm oil or palm derivatives, including materials purchased through intermediaries.
• Trace upstream sources. Determine the plantations, mills, refiners, traders, and processors connected to those materials, with immediate attention to MAR and HIP.
• Test documentation. Confirm that supplier records can substantiate chain of custody and admissibility before a shipment is detained.
• Address gaps. Strengthen supplier questionnaires, contractual disclosure requirements, audit rights, and escalation procedures where origin information is incomplete.

A&M Insight

Companies that use palm oil should not wait for a detention to investigate sourcing. A focused review should identify affected products, trace palm inputs beyond Tier 1 suppliers, test supporting records, and remediate visibility gaps. Importers that can promptly document source and chain of custody will be better positioned to reduce detention risk and business disruption.

Sources

Please find links to the WRO notices from CBP:

CBP issues Withhold Release Orders on Mitra Aneka Rezeki and Hardaya Inti Plantation | U.S. Customs and Border Protection

CSMS # 70061795 – Withhold Release Orders (WROs) on palm oil and its derivative products produced in Indonesia by Mitra Aneka Rezeki and Hardaya Inti Plantation

https://www.alvarezandmarsal.com/thought-leadership/cbp-withhold-release-orders-two-target-indonesian-palm-oil-producers