Modern Slavery Enforcement

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April has seen enforcement actions on Chinese work gloves, South Korean Sea Salt, and most recently a petition based on evidence of modern slavery in the Brazilian coffee industry.

Brazilian Coffee

On April 24, 2025, Coffee Watch submitted a petition to Pete R. Flores, Acting Commissioner of U.S. Customs and Border Protection (CBP), under Section 307 of the Tariff Act of 1930 (19 U.S.C. § 1307). The petition requests that CBP issue a Withhold Release Order (WRO) against the importation of coffee and coffee products from Brazil by Starbucks Corporation, Nestlé S.A. and Nestlé U.S.A., Jacobs Douwe Egberts (JDE), Dunkin’, Illy Caffè, and McDonald’s.

Coffee Watch alleges that these companies import coffee beans produced “wholly or in part” with forced labor from Brazil, in violation of U.S. law. The petition cites evidence of systemic forced labor practices, including debt bondage, abusive living and working conditions, and coercion on coffee farms supplying the Cooxupé cooperative, a major supplier to Starbucks and Nestlé. Specific farms cited include Sítio Coqueiros, Sítio da Ilha, Córrego do Jacu, Paquera, and Sítio São João, all located in Minas Gerais, Brazil’s principal coffee-growing region.

Four producers affiliated with Cooxupé (Regional Cooperative of Coffee Growers in Guaxupé), the world’s largest Arabica coffee cooperative, were added to Brazil’s Dirty List for slave labor, updated by the Brazilian Labor Ministry (MTE) on April 9. The farmers were included in the list after labor inspectors identified 36 workers—among them a teenager—working under conditions analogous to slavery on farms in Minas Gerais state.  The company exports coffee beans to clients such as Melitta, Lavazza, JDE (owner of the L’OR brand), and Starbucks, according to export records.

Despite certificates and audits, the violation of the rights of agricultural laborers in coffee farming persists in Brazil. This is the conclusion of the study “Plagues on farmland”, prepared by Conectas in partnership with the Dutch organization SOMO  [link to report]

Chinese Work Gloves

Effective April 10,2025 , U.S. Customs and Border Protection (CBP) personnel at all U.S. ports of entry will detain work gloves manufactured by Shanghai Select Safety Products Company, Limited and its two subsidiaries from China, Select (Nantong) Safety Products Co. Limited and Select Protective Technology (HK) Limited.

CBP issued a Withhold Release Order (WRO) against Shanghai Select Safety Products Company, Limited and its two subsidiaries Nantong and HK, based on information that reasonably indicates the use of convict labor in violation of 19 U.S.C. § 1307 in the production of that merchandise.

Korean Sea Salt

April 3, 2025:  CBP issued a Withhold Release Order (WRO) against Taepyung Salt Farm based on information that reasonably indicates the use of forced labor in violation of 19 U.S.C. § 1307 in the production of the company’s sea salt products yesterday. Effective immediately, CBP personnel at all U.S. ports of entry will detain sea salt products sourced from Taepyung Salt Farm in South Korea.

CBP identified the following International Labour Organization forced labor indicators during its investigation of Taepyung Salt Farm: abuse of vulnerability, deception, restriction of movement, retention of identity documents, abusive living and working conditions, intimidation and threats, physical violence, debt bondage, withholding of wages, and excessive overtime.

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