Withhold Release Order (WRO) Response Support
Restoring trade access through credible, third-party investigations
Helping organisations 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 organisations in meeting CBP requirements. Our experts combine on-the-ground experience and regulatory insight to identify root causes, design effective remediation programmes and confirm compliance through credible reporting.
Our WRO response 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
Following an investigation, we develop detailed, time-bound remediation plans tailored to your business and suppliers. These plans focus on addressing root causes, such as repayment of recruitment fees, improving living and working conditions, and implementing sustainable management practices.
Capacity building and training
To drive sustainable improvement, LRQA provides targeted training and capacity building programmes for your teams and suppliers. These initiatives focus on responsible recruitment, risk identification, and compliance with international labour standards, helping to prevent recurrence.
Why work with us?
Global capability
We’re everywhere you are. With experienced investigators and consultants worldwide, we deliver a consistent, high quality, service providing local insight with international reach and credibility.
Flexible delivery
Whether you require an urgent investigation, ongoing remediation support, or supplier training, we tailor our services to your specific needs. Our modular approach allows us to adapt quickly.
A history of firsts
LRQA is a trusted partner to law firms providing support for entities responding to CBP and for brands, global brands and suppliers in high risk countries responding to and address forced labor allegations.
Sustainable focus
Our work goes beyond compliance. We help organisations 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.
What types of forced labour indicators are assessed in a WRO investigation?
The International Labour 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.
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
