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FORCED

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ADVISORY

LABOR

December 2000

1

Advisory

International Child Labor Enforcement

U.S. Customs Service

CONTENTS

I. Introduction ................................................................................................................... 3

II. Forced or Indentured Child Labor in Export Industries ............................................. 4

III. Legal Framework Prohibiting Importation of Merchandise

Produced with Forced or Indentured Child Labor ...................................................... 4

IV. Indicators........................................................................................................................ 5

A. Red Flags .................................................................................................................. 6

B. Yellow Flags .............................................................................................................. 8

V. Means of Establishing that Merchandise was Not Produced with

Forced or Indentured Child Labor: Effect of Monitoring, Verification,

and Contractor Compliance Organizations and Systems ............................................ 9

VI. U.S. Customs Enforcement Actions ............................................................................ 10

A. Detention orders ..................................................................................................... 10

B. Findings .................................................................................................................. 10

C. Public list of detention orders and findings........................................................... 11

VII. Importer’s Opportunity to Establish Admissibility of Merchandise

under Detention or Subject to a Finding .................................................................... 11

Appendix A: Statutory and Regulatory Framework Prohibiting Importation

 of Merchandise Produced with Forced or Indentured Child Labor ...................... 13

Civil Sanctions.............................................................................................................. 13

Criminal Sanctions....................................................................................................... 14

Appendix B: Resources for Voluntary Compliance by Industry ........................................... 15

I. Information Sources ................................................................................................ 15

II. Additional Safeguards............................................................................................ 16

Appendix C: Guidance for Factory Monitors ........................................................................ 17

Steps that Monitors Can Take to Determine if Forced or

Indentured Child Labor is Present in the Workplace ................................................ 17
2

I. Consult Knowledgeable Local Information Sources about Labor Conditions... 17

II. Interview Workers................................................................................................. 17

III. Interview Management ......................................................................................... 18

IV. Capacity Review.................................................................................................... 20

V. Visual Inspection ................................................................................................... 20

Appendix D

 List of Customs Attachés ...................................................................................... 21
3

ADVISORY

International Child Labor Enforcement

U.S. Customs Service

I. Introduction

This Advisory provides important information intended to help importers, manufacturers, retailers, trade

association officials, attorneys, customs brokers and freight forwarders, and other businesses involved in

importing merchandise from foreign countries, or advising their clients and member companies regarding

import transactions, identify merchandise that may be produced with forced or indentured child labor under

penal sanction1 and thereby facilitate voluntary compliance with federal law prohibiting the importation of

goods produced with forced or indentured child labor.

The Advisory describes the types of working conditions that may, in the view of the U.S. Customs Service,

signal the presence of forced or indentured child labor. The Advisory presents two sets of indicators, “red

flags” and “yellow flags,” that importers and others can use in seeking to determine whether specific

merchandise is likely to be prohibited from importation on the grounds that it was produced with forced or

indentured child labor. The indicators track the kind of evidence that the U.S. Customs Service considers in

determining whether merchandise should be denied importation.

The first group of indicators identifies “red flags,” factors that alone, or with other available information,

strongly imply that a supplier in a foreign country may be using forced or indentured child labor, or sourcing

from a facility that does so. In general, these red flags should raise serious suspicion on the part of importers

and others involved in importing merchandise into the United States that forced or indentured child labor is

being employed.

The Advisory also identifies “yellow flags,” working conditions or business practices that, while not necessarily

constituting direct evidence of forced or indentured child labor, should create suspicion on the part of importers

that unfair or illegal labor practices, possibly including employment of forced or indentured child workers,

might be involved. At a minimum, yellow flags generally warrant further serious inquiry and investigation.

The Advisory also briefly explains the legal framework under which the U.S. Customs Service operates and

the procedures it follows in enforcing the law. In addition, it identifies a number of possible information

sources and procedures that may help importers and others identify goods produced with forced or indentured

child labor. It is hoped that this information will encourage individual companies, trade associations, and

1 As used in this document, “indentured child labor” refers to “indentured child labor under penal sanction,” as specified by

19 U.S.C. § 1307.
4

business advisors to adopt checklists, practices, and industry guidelines that will reduce the risk of becoming

engaged in an import transaction involving merchandise produced with forced or indentured child labor.

Informed, voluntary compliance on the part of importers is good, common sense business practice and helps

avoid monetary penalties and/or shipments being detained, and possibly seized and forfeited, by U.S. Customs.

II. Forced or Indentured Child Labor in Export Industries

Abusive child labor is one of the most serious worker and human rights issues facing the world trading

community. Studies conducted by the U.S. Department of Labor, the International Labor Organization (ILO),

and a number of non-governmental organizations (NGOs) indicate that child labor is endemic in many parts

of the developing world. The ILO estimates that there are approximately 250 million child workers worldwide.

Child labor can be found in many industries that produce goods for export, including the production and

processing of hand-knotted carpets, apparel, footwear, brassware, silk, glassware, bricks, furniture, food,

gems, and leather.2 Some of the industries in which children are employed are hazardous, such as production

of fireworks and matches, glass blowing, and mining. Other occupations are not necessarily intrinsically

dangerous, but often expose working children to hazards such as airborne pollutants, pesticides and herbicides,

and other health risks. In some countries, government policies to promote exports of low-skilled, laborintensive products, such as garments and carpets, may have resulted in an increase in the demand for and use

of child labor, which may be forced or indentured. (See By the Sweat and Toil of Children: The Use of Child

Labor in American Imports (vol. 1), U.S. Department of Labor, July 15, 1994.)

Not every forced or indentured labor situation involves openly cruel and abusive circumstances, but employment

at a tender age; excessively long work hours; virtual imprisonment, including physical restraints; use of

physical force and abuse to enforce the work obligation; a debt that can never be discharged and that in fact

grows larger, are all too common, and signal the possible presence of forced or indentured child labor.

III. Legal Framework Prohibiting Importation of Merchandise Produced with

Forced or Indentured Child Labor

Section 307 of the Tariff Act of 1930 (19 U.S.C. § 1307) prohibits the importation of merchandise produced

in whole or in part with prison labor, forced labor, or indentured labor under penal sanction. Forced labor

includes “all work or service . . . exacted from any person under the menace of any penalty for its nonperformance

and for which the worker does not offer himself voluntarily” (19 U.S.C. § 1307). The law applies to goods

produced by convict labor, forced labor, or indentured labor under penal sanctions performed by a person of

any age. It was amended this year to make explicit that forced labor or indentured labor under penal sanction

2 The industriesnoted above are the primary export industries employing child labor. While child labor involved in these industries

is not necessarily forced or indentured, businesses seeking to import these kinds of products need to be aware that child labor is

most commonly found in these products, and to take appropriate steps to make sure that the goods they seek to import are not in fact

made with prohibited forced or indentured child labor.
5

includes forced or indentured child labor.3 (P.L. 106-200, Title IV, § 411(a), 114 Stat. 298) (Appendix A

discusses Section 307 and related Customs regulations in greater detail.)

The law applies to merchandise produced “wholly or in part” with prohibited labor. Accordingly, a product

must be free of components produced with forced or indentured labor to qualify for admissibility into the

United States. For example, carpets produced in a carpet factory that does not itself employ prohibited child

labor in the carpet weaving would nonetheless not be eligible for import into the United States if the factory

relied on a supplier of yarn that used forced or indentured child labor in carding, spinning, and/or dyeing wool.

The U.S. Customs Service enforces Section 307 and related regulations. Under Section 307, the Customs

Service excludes from entry into the commerce of the United States any goods, wares, articles, and merchandise

that it has reason to believe were mined, produced, or manufactured in a foreign country with forced or

indentured child labor. (See Part V of this Advisory, discussing Customs enforcement actions.)

IV. Indicators

The nature of child labor in developing countries can sometimes make it difficult to determine whether

merchandise has been produced in whole or part using forced or indentured child labor. Documentary evidence,

such as a copy of a formal contract of indenture consigning a child to work for a term of years to pay off a debt,

is not usually available. Indeed, a child may be consigned to a lengthy, and possibly abusive, indentured labor

situation on the basis of a handshake and a lump sum cash payment from the employer to a relative of the child

or a middleman.

Accordingly, voluntary compliance with U.S. law may, in individual cases, require importers and others

involved in import transactions to seek to obtain and evaluate information about the circumstances involved in

producing particular goods. Importers should attempt to consult the types of sources used by the U.S. Customs

Service in seeking information about forced or indentured child labor, including oral or written testimony or

circumstantial evidence from social workers; operators of children’s shelters; police and other local government

officials; employees of international organizations; child workers or former child workers; and other

knowledgeable parties. Direct evidence, including testimony of children currently working as forced or

indentured laborers or former child workers, is obviously highly probative. In addition, circumstantial evidence

3

It should be noted that Section 307 does not apply to all child labor, only to forced or indentured child labor. Thus, if child labor

is not forced or indentured, Section 307 does not prohibit the importation of products of child labor simply because a child was

under the legal age for work in the relevant country or, as a minor, was incapable of entering into a binding legal contract of

employment. Moreover, working in response to extreme economic pressure, including pressure to earn a livelihood due to severe

poverty in a developing nation, does not necessarily constitute “forced labor” within the statutory definition. It must be emphasized

that although 19 U.S.C. § 1307 was recently amended to emphasize that its prohibition includes forced or indentured labor by

children, the statute prohibits forced or indentured labor by persons of any age, not just by children. U.S. trade laws and Customs

regulations do not define “child” or “child labor,” and do not contain any reference to any particular age.
6

may also strongly indicate that abusive child labor practices, including forced or indentured child labor, are

involved.

There is no sharp distinction between red and yellow flag indicators. Yellow flags differ from red flags

primarily in that yellow flag factors are more generic and do not necessarily specifically indicate forced or

indentured child labor. A yellow flag may signal the need for additional investigation to determine whether

forced or indentured child labor is being performed in a facility.

In contrast, the presence of red flag conditions alone may provide sufficient grounds for the importer to decide

that there is a serious risk that goods were produced with forced or indentured child labor, and to avoid

seeking to import them on this basis. Red flag indicators are sufficiently strong that if clearly established, the

Customs Service may base enforcement action on them alone. In any given individual factual setting, however,

further investigation may reveal an innocent explanation for one or more red flags, while additional investigation

of a yellow flag may disclose evidence of forced or indentured child labor.

A single factor evidencing harsh, abusive, or coercive conditions, such as slave labor conditions or indications

of physical abuse, may provide strong evidence of forced or indentured child labor. Such indicators should be

taken as raising a very serious warning to importers and others that merchandise produced under these conditions

involves a high risk that it would be prohibited from importation. Moreover, the presence of numerous other

factors may have a cumulative effect in supporting an inference that child labor is forced or indentured.

A. Red Flags

The following should be considered “red flags,” factors that the Customs Service regards as strong

indicators of forced or indentured child labor, upon which the Customs Service may base enforcement

action or further investigation. This list is not exclusive. Importers should consider any other pertinent

factors that may tend to establish that child labor is forced or indentured and that the child is not offering

himself or herself for employment voluntarily. In choosing suppliers, importers should make inquiries

and adopt other safeguards to avoid suppliers where there is a high risk that such conditions may be

present. (See Appendix B and C.)

(1) Slave labor conditions. Slave labor conditions exist when a child is a virtual prisoner and is

not free to choose to leave the work site and the employment. Evidence of slave labor may

include (i) the use of chains and other physical restraints; (ii) physical confinement in or

restricted egress from a facility, especially where a facility is locked and/or guarded, and the

locked gates and doors and/or the presence of police or guards appear to exceed reasonable

needs for the physical security of plant, equipment and inventory; (iii) use of physical force or

abuse to keep the child at the workplace; (iv) the involvement of private or public police or

security guards to return runaway workers to the job site and to enforce the work obligation

by violence or imprisonment; and (v) isolated work sites, such as jungle camps or platforms at

sea, where children are prevented from leaving, even at the end of an agreed term of service,

by the inaccessibility of transportation not controlled by the employer.

(2) Employment to discharge a debt or debt bond. This is the one of the main elements of

indentured labor under penal sanctions under Section 307.
7

(3) Payments made to a party other than the worker. This often indicates that the employment

is indentured to pay off the debt of another, for example, a parent. While payment to a parent

may represent an acceptable business practice, adopted because a child is a minor, the

circumstances surrounding such payment should be examined to determine if it indicates that

the parent is being paid for the child’s indentured labor.

(4) Financial penalties for absenteeism, production errors, or refusal to work overtime, where

such penalties eliminate wages or credits already earned or create indebtedness that

must be discharged. These and other manipulations of worker compensation to perpetuate

and even enlarge the worker’s indebtedness and create indefinite bondage may constitute

persuasive evidence of forced or indentured child labor.

(5) Evidence of physical or sexual abuse of child workers at the workplace. Physical

intimidation of workers to keep them on the job, forestall complaints to authorities, and punish

mistakes, is frequently an earmark of forced or indentured child labor.

(6) Employment of very young children. No specific age raises a red flag. However, while a

child slightly under legal work age may voluntarily skirt the law to earn money, the presence

of children of tender age in the workplace, particularly in significant numbers, is likely to

signal that they have been put to work involuntarily.

(7) Children who by their appearance seem to require immediate medical or psychological

care by reason of an apparent physical or mental infirmity. The presence in a work situation

of child workers who appear to be in such poor physical or mental condition that immediate

medical or psychological care seems necessary may indicate forced or indentured child labor.

(8) Employment of children not working as part of a family unit nor in the presence of a

parent or other adult family member. Especially when children of tender years are working

in a situation that does not involve the family unit or the presence of a parent or other adult

family member who can look out for the child’s interest, forced or indentured child labor may

be present. However, the presence of an adult family member or family unit does not by itself

insulate employment from a finding of forced or indentured labor on the part of the child

where other evidence suggests that the child’s labor is forced or indentured.

(9) Girls working without adult female presence or supervision where this is contrary to

local custom. Girls are particularly vulnerable to being exploited in child labor situations.

For girls in many developing nations, work away from the family setting, including forced or

indentured labor, is often a weigh-station to forced prostitution. This risk is reinforced by the

physical vulnerability of girls and the culture in some developing nations that devalues women

and girls and discourages them from openly asserting their rights and interests. In a number of

cultures, it is considered “out of place” and “not right” for girls, particularly of tender years,

to be working outside the family and without adult female presence, and these conditions

therefore may correlate with the girls’ forced or indentured labor.
8

(10) Employment of children at a work site remote from their hometown or village. Various

studies indicate that child workers are often “collected” from their homes by a middleman and

transported to a work site some distance away, where they are effectively removed from parental

guardianship and subject to the dictates of the employer.

B. Yellow Flags

(1) Work being performed during unusual hours, such as early morning or late at night or

when a child could be expected to be in school. This may indicate that very long and

excessive hours are being worked. Such circumstances may be very prejudicial to the health

of child workers and their prevalence at a work site may correlate with children working under

compulsion.

(2) Poor and unhealthy working environment, including, but not limited to, poor lighting

and ventilation, and/or lack of access to food, water, and sanitary facilities. While poor

working conditions may be encountered by persons working voluntarily, neglect by the employer

of basic worker amenities has a high correlation with abusive labor practices, including forced

or indentured child labor.

(3) Employment in violation of local laws and regulations. Plants that violate local labor laws

present a higher risk of forced or indentured child labor.

(4) Employment in hazardous industries or under extreme conditions. Children working in

hazardous occupations or under hazardous conditions are more likely to have been coerced

than children working in more age-appropriate, less dangerous situations. ILO Convention

182 To Abolish the Worst Forms of Child Labor provides internationally negotiated guidelines

regarding types of child labor that are considered unacceptable to the world community.

(5) Missing or altered employment records. Careless, incomplete, or unethical recordkeeping,

especially altered or destroyed records, may conceal illegal business practices, including use

of prohibited sources of labor.

(6) Workers missing from looms or other workstations that are in active operation during

on-site visits. Certain workstations require a specific crew to operate them. For example, a

carpet loom may require four workers seated side by side to do the weaving. Where a loom is

in active operation and two workers are missing during a plant inspection, the missing workers

may be underage or forced or indentured child workers.

(7) Denial of generally available educational opportunities. Although educational opportunities

for children may be very limited in certain developing countries or in specific regions of these

countries, the denial of education generally provided to children of the child worker’s age in

the locality where the child is working may indicate that the situation involves forced or

indentured child labor.
9

V. Means of Establishing that Merchandise Was Not Produced with Forced

or Indentured Child Labor: Effect of Monitoring, Verification, and

Contractor Compliance Organizations and Systems.

In seeking to establish that merchandise has not been produced with prohibited forced or indentured child

labor, importers may wish to use the following measures:4

(1) Independent monitoring and labeling systems. In deciding whether merchandise is admissible

under Section 307, the Customs Service may take into account the membership and participation

by the manufacturer, exporter, or importer in an independent external monitoring, inspection,

or labeling program, such as a reliable program, either private or government-sponsored, that

certifies that an exported product was not manufactured with child labor. The certification

may, for example, take the form of a distinctive label attached to the exported product indicating

that it is a child-labor free product.

(2) Report of an independent private verification firm. The Customs Service may also consider a

report prepared by an independent private verification service or firm that (i) a specific export

or shipment was not produced with forced or indentured child labor or (ii) that a given facility

does not utilize such labor. A report of such a verification service may be based, for example,

on an on-site investigation of a plant in a foreign country, documenting that it does not employ

forced or indentured child labor. One approach to best practices for factory monitors is the

guidelines established by the Fair Labor Association, set forth in Appendix C.

(3) Corporate in-house contractor compliance and verification programs. Many businesses rely

on their own, detailed in-house contractor compliance and verification systems to protect

themselves from involvement with unreliable suppliers who may be using unfair and/or illegal

labor practices, including forced or indentured child labor. In-house procedures may incorporate,

or be modeled on, best practices or codes established by specific industries for use by their

members.

(4) Evidentiary effect of using verification methodologies. Evidence that an importer has used

one or more of the methodologies described in subparagraphs (1), (2) and (3) above to avoid

using a prohibited source of labor to produce an imported product will be considered in

conjunction with all the facts and circumstances surrounding the importation.

(5) Reliance on verification and other preventive safeguards does not establish an entitlement to

import the goods. The use of verification and other preventive measures to avoid involvement

with merchandise produced with a prohibited source of labor may help establish “due diligence”

and tend to rebut an inference of a willful violation, and certainly reduces the risk of a violation,

but does not establish a right to import the merchandise. Where the Customs Service finds that

merchandise falls within Section 307’s prohibition, it must be exported or otherwise disposed

of in accordance with the Customs regulations, regardless of the good faith of the importer.

4 The U.S. Customs Service will determine the admissibility of merchandise and cannot delegate its responsibility to investigate

violations of Section 307 and to take appropriate enforcement actions. However, in assessing proof of admissibility offered by an

importer under Section 12.43 of the Regulations, the Customs Service may consider these measures, among other evidence. The

U.S. Customs Service does not endorse any specific code or organization.
10

VI. U.S. Customs Enforcement Actions

The U.S. Customs Service emphasizes the importance of avoiding importing goods produced by forced

labor, including forced child labor.5 Customs encourages voluntary action by importers to avoid importing

such goods. However, in the absence of voluntary compliance by importers, Customs may take one of two

types of enforcement action under Section 307 and related regulations to keep goods or merchandise produced

in a foreign country with forced or indentured child labor from entering United States commerce when such

goods are sought to be imported.6 These are: (1) provisional detention of the merchandise, which may apply

to an individual shipment or to the entire output of a type of product from a given firm or facility or (2) a more

formal finding that the class of merchandise is the product of forced or indentured child labor, which bars it

from the U.S. market while the finding remains in effect. Each of these enforcement actions is discussed in

more detail below.7

Customs Service detention orders and findings are product and producer specific. Customs identifies

merchandise subject to Section 307 by the type of merchandise, the foreign manufacturer that is the source of

the goods, and the form of prohibited labor. 8 The law does not authorize categorical restrictions on all imports

of a given product from a given country because some products of that kind from that country are produced by

forced labor. However, once information is obtained by Customs that reasonably, but not conclusively, indicates

that a particular foreign manufacturer is using a prohibited class of labor to produce a particular type of

product, all imports of that product from that firm would be subject to detention. The burden then would shift

to the importer to attempt to prove that any particular shipment or production run was not actually produced

with a prohibited source of labor.

A. Detention Orders

Under Section 12.42(e) of the Customs regulations, if the Commissioner of Customs finds that available

information reasonably but not conclusively indicates that imported merchandise has been produced

with forced or indentured child labor, Customs may detain the merchandise in Customs’ custody. The

importer has an opportunity within three months to demonstrate that the merchandise was not produced

with forced or indentured child labor. (Section 12.43 of the Customs regulations). Under Section 12.44

of the Regulations, the importer may elect to export the merchandise, provided no finding has been

issued, as discussed below.

5

In 1999, the Secretary of the Treasury established the Treasury Advisory Committee on International Child Labor Enforcement.

The Committee, chaired by the Assistant Secretary (Enforcement), makes recommendations to the Treasury Department and the

U.S. Customs Service to strengthen forced or indentured child labor enforcement, in particular, through voluntary compliance and

business outreach.

6 Customs proceeds on a case-by-case basis and uses a variety of law enforcement investigative methods to determine whether an

imported product is subject to Section 307’s prohibition of goods made with forced or indentured child labor, and thus subject to

an enforcement action.

7 To enhance its enforcement efforts against forced or indentured child labor imports, in Fiscal Year 1999, the U.S. Customs Service

assigned two additional child labor investigators to Bangkok, one to Hong Kong, and one to Montevideo. In Fiscal Year 2000, the

U.S. Customs Service assigned an agent to Panama City. A list of Customs’ attachés is provided in Appendix D.

8 Thus, a Customs Service detention order takes the form of the following actual detention order that identifies a product and an

originating overseas manufacturer: 7/21/98 Carpets, Hand-Knotted Wool – Kumar Carpet Pvt. (Nepal).
11

B. Findings

If, after investigation, the Commissioner finds probable cause that a class of merchandise (typically

defined as a category of merchandise, or even all merchandise, originating from a particular manufacturer,

facility, or distributor) is produced with forced or indentured child labor, he will make a finding to that

effect. Such findings are reviewed and approved by the Secretary of the Treasury and published in the

Customs Bulletin and the Federal Register. Entry of merchandise subject to a finding is denied. Customs

recently amended its regulations to provide for seizure and forfeiture of merchandise that is presented for

importation when a finding covering the merchandise is in effect. (See Appendix A.)

C. Public List of Detention Orders and Findings

The U.S. Customs Service publishes a complete list of outstanding detention orders and

findings on its website, http://www.customs.gov, and also in the Customs Bulletin.

VII. Importer’s Opportunity to Establish Admissibility of Merchandise

Under Detention or Subject to a Finding

If an importer believes that goods that have been detained or barred from entry by the U.S. Customs Service

are not subject to Section 307, it may take steps to verify that the merchandise was not produced with a

prohibited form of labor. Section 12.43(a) of the Customs regulations provides a certificate of origin form,

which, when completed by the foreign seller or owner of the imported article, may be used to attest that the

article was not produced with a prohibited form of labor. The certificate must be filed with the Customs

Service within three months of the date of import.

In addition, the importer must submit to the Customs Commissioner, within three months of the date of

import, a statement from the ultimate consignee of the merchandise, showing in detail that the ultimate consignee

(i) had made every reasonable effort to determine the source and form of labor used to produce the merchandise,

including each of its components, (ii) the full results of his investigation, and (iii) his belief with respect to the

use of the class of labor specified in the finding in any stage of the production of the merchandise or of any of

its components. (Section 12.43(b)).

If the importer’s certificate or certificates and the ultimate consignee’s statements are submitted within the

prescribed time and the Commissioner finds that the merchandise is admissible, the relevant port director will

be advised and shall release the merchandise upon compliance with the usual entry requirements. (Section

12.43(c)).
12

REPORT MERCHANDISE PRODUCED WITH CONVICT, FORCED,

OR INDENTURED LABOR BEING IMPORTED INTO THE UNITED STATES

TO THE U.S. CUSTOMS SERVICE.

Under Section 12.42(b) of the U.S. Customs regulations, any person outside the U.S. Customs Service who

has reason to believe that merchandise being imported into the United States, or likely to be imported, has

been produced with convict, forced, or indentured labor under penal sanction may report the information,

with appropriate supporting evidence, as follows:

Commissioner of Customs

Ronald Reagan Building

1300 Pennsylvania Avenue, NW

Washington, DC 20229

U.S. Customs Hot Line: 1-800-BE-ALERT (in the Continental U.S.)

Email: forcedlabor@customs.treas.gov

Website: http://www.customs.gov,

Fraud investigations telephone: 202-927-1510

The information provided in this publication is for general information purposes only. Recognizing that many

complicated factors may be involved in customs and international trade compliance issues, an importer, or a

manufacturer using overseas production facilities, may wish to obtain advice from an expert who specializes

in Customs matters and/or trade compliance and/or contractor compliance, and should take all reasonable

steps to determine the type of labor being utilized to produce merchandise which it intends to import into the

United States. Reliance solely on the general information in this Advisory may not be sufficient to ensure

compliance with the applicable law, including 19 U.S.C. § 1307.
13

APPENDIX A

Statutory and Regulatory Framework Prohibiting Importation of Merchandise Produced with

Forced or Indentured Child Labor

19 U.S.C. § 1307: Section 307 of the Tariff Act of 1930, 19 U.S.C. § 1307, generally prohibits

the importation of any merchandise that is mined, produced, or manufactured using convict,

forced, or indentured labor under penal sanctions. Congress recently amended this provision to

emphasize: “For purposes of this section, the term “forced labor or/and indentured labor”

includes forced or indentured child labor.” (Section 307 of the Tariff Act of 1930 (19 U.S.C. §

1307), as amended, Public Law 106-200, Title IV, Section 411, 114 Stat. 298 (May 18, 2000).

Customs enforces this prohibition under its regulations at 19 CFR §§ 12.42-12.45.

These regulations authorize Customs to detain merchandise in its custody if the Commissioner

of Customs finds that the information available reasonably, but not conclusively, indicates that

the merchandise has been produced with forced child labor or indentured child labor under penal

sanction. 19 C.F.R. § 12.42(e). The importer may export detained merchandise at any time

before it is seized and denied entry based on a finding, after investigation by the Customs Service,

of probable cause that it was produced with forced or indentured child labor.

19 C.F.R. §§ 12.42(f), 12.44. The importer has an opportunity within three months from the

date the merchandise was imported to demonstrate that it was not produced with forced or

indentured child labor. 19 C.F.R. § 12.43. Where merchandise is subject to a detention order and

proof is not timely submitted or does not establish the admissibility of the merchandise, the

merchandise will be deemed abandoned and destroyed 60 days after notice is issued to the

importer that the merchandise will be excluded from entry, unless it has been exported or a

protest has been filed. Finally, under recently amended Customs regulations implementing Section

307, after investigation by the Customs Service, goods covered by a finding under 19 C.F.R. §

12.42(f) of probable cause that they were produced with forced or indentured child labor are

subject to seizure and forfeiture. 19 C.F.R. § 12.44(b).

In addition to Section 1307 and its implementing regulations, a number of other Customs and

Criminal Code provisions may apply in specific cases. These provisions are summarized below.

CIVIL SANCTIONS:

19 U.S.C. § 1592 : This statute provides for significant civil monetary penalties for material false

statements and other material false acts/omissions, resulting from fraud, gross negligence, and

negligence, related to introducing or attempting to introduce merchandise into the United States

contrary to law. The amount of the penalty equals the value of the goods introduced or attempted

to be introduced into the United States. Accordingly, a person involved with the introduction or

attempted introduction of goods made with forced child labor or indentured child labor under

penal sanctions would be subject to a civil penalty equal to the value of the proscribed goods if

such false statements, acts, or omissions were made in connection with the importation. In

addition, under certain circumstances, Section 1592 also authorizes the civil forfeiture of the

imported merchandise.
14

19 U.S.C. § 1595a(b): This provision authorizes a civil penalty equal to the value of any

merchandise introduced or attempted to be introduced into the United States contrary to law.

CRIMINAL SANCTIONS:

18 U.S.C. § 545: Under 18 U.S.C. § 545, it is a felony for a person to fraudulently or knowingly

import or bring into the United States merchandise contrary to law. Thus, a person who, with

the required criminal intent, brings merchandise into the United States in violation of Section

307, may be subject to prosecution under Section 545. Section 545 also punishes persons who

receive, conceal, buy, sell, etc., any merchandise after importation, knowing the merchandise has

been imported contrary to law. Accordingly, a person who fraudulently or knowingly imports

goods made with forced or indentured under penal sanctions child labor, or engages in any of the

subsequent activities mentioned above (e.g., transportation or sale thereof), would be liable to

prosecution for violating Section 545. In addition, 18 U.S.C. § 545 authorizes the civil forfeiture

of any merchandise introduced into the United States in violation of this section.

18 U.S.C. § 542: This provision makes it a felony to enter or introduce merchandise into the

commerce of the United States by means of false statements, etc., or to make a false statement in

any declaration without reasonable cause to believe the truth of such statement.
15

APPENDIX B: RESOURCES FOR VOLUNTARY COMPLIANCE BY INDUSTRY.

The U.S. Customs Service seeks to obtain informed and voluntary compliance with all customs and

trade laws. This Appendix identifies sources of information and sets out steps that importers may take

that may help reduce the risk of becoming engaged in a transaction involving imported merchandise

produced with forced or indentured child labor.

I. Information Sources

(1) U.S. Department of Labor reports. The United States Department of Labor has

produced a series of reports on child labor, By the Sweat and Toil of Children,

Volumes I –VI, that contain extensive information on countries and industries

where child labor is believed to be prevalent.

(2) U.S. Department of State human rights reports. The U.S. Department of State

files an annual volume, Country Reports on Human Rights Practices, with the

House Committee on International Relations and the Senate Foreign Relations

Committee. The report documents human rights conditions, including child

labor, for every nation.

(3) U.S. Embassy sources. An importer may wish to consult the office of the

Economic Minister or Counselor at the U.S. Embassy in a country in which it

wishes to do business. In addition, the U.S. Department of Commerce may have

commercial representatives at a given embassy or consular post who may be able

to furnish information regarding potential business partners. U.S. Customs also

has attachés stationed at a number of embassies. (See Appendix D.) A number

of the Customs attachés have specific backgrounds in prison labor and forced or

indentured child labor enforcement.

(4) International organizations. International organizations, such as the International

Labor Organization (ILO) and the United Nations Children’s Fund (UNICEF),

issue reports on child labor, as do a variety of non-governmental organizations

(NGOs) dedicated to human rights, worker rights, and child welfare.

(5) Local non-governmental organizations in the exporting country. Apart from

the well-known international organizations referred to above, there are many

local organizations in developing nations committed to protecting children’s rights.

These organizations are often valuable resources in identifying contractors to

avoid, and also suggesting reliable contractors who have pledged to support efforts

to eliminate child labor from their industries.

(6) Labor unions in the exporting country. Local labor unions are likely to have

useful information about working conditions in various companies, and will be

aware of companies that demonstrate concern for workers’ rights and welfare

through their relationships with the unions and other workers’ organizations.

Unions may also be able to arrange interviews with current or former employees

of contractors with whom the importer is considering establishing a business

relationship.
16

(7) Manufacturers’ and exporters’ associations and other trade and business

groups in the exporting country. Local manufacturers’ and exporters’

associations in exporting countries may have adopted codes against unfair labor

practices, including child labor and bonded labor, which is contrary to law in

many of these countries. Members are required to follow the codes as a condition

of membership in the association and may be expelled if they violate the codes.

These associations can provide current lists of members who honor their standards

and may be able to furnish information about non-member businesses in their

industries.

II. Additional Safeguards

(1) On-site inspections. An on-site inspection may disclose the presence of one or

more red or yellow flags identified in this advisory, and/or produce valuable

information about a supplier’s capability to fulfill a contract without using a

prohibited source of labor or without subcontracting to another facility that may

do so. This is a matter of “knowing your supplier.”

(2) Industry codes and checklists. A number of U.S. companies and trade

associations in the toy, apparel, and other industries have developed detailed

codes and checklists to promote compliance with core labor standards. Volume

III of the U.S. Labor Department By the Sweat and Toil of Children series,

entitled The Apparel Industry and Codes of Conduct: A Solution to the

International Child Labor Problem?, reprints a number of these codes.
17

APPENDIX C

GUIDANCE FOR FACTORY MONITORS

STEPS THAT MONITORS CAN TAKE TO DETERMINE IF FORCED OR INDENTURED

CHILD LABOR IS PRESENT IN THE WORKPLACE

Importers and others involved in import transactions may want to use the services of verification

companies that actively investigate the conditions under which merchandise for export is produced.

In availing themselves of these services, importers should make sure that verification efforts include

appropriate steps to determine whether goods have been produced in whole or part with prohibited

forced or indentured child labor. These steps can include the following:

I. Consult knowledgeable local information sources about labor conditions.

 (For a list of available information sources about local labor conditions, see Appendix B.)

(1) Inquire into whether instances of forced or indentured child labor are

known or suspected in the area.

(2) Determine whether the government is known or suspected to tolerate

or acquiesce in child labor in export industries.

(3) If migrant labor is used locally, check whether contract terms typically

limit child workers’ ability to leave their jobs before their contract expires.

(4) If recruitment agencies are used, ask whether they limit child workers’

freedom to leave their jobs before their contracts expired, or whether

child workers or their families are forced to pay substantial fees to these

agents.

(5) Inquire about restrictions on child workers’ freedom of movement in

local factories that may suggest forced labor.

(6) Identify methods for verifying workers’ ages that are particularly useful

or futile in the local area.

(7) Identify interview techniques and questions that may be particularly useful

in verifying workers’ ages.

II. Interview Workers

(1) Ask how child workers arranged for terms of employment and whether

they were aware of their right to decide whether or not to accept

employment under these terms.

(2) Determine whether any side agreements exist that require payments

violating the terms of employment.
18

(3) Interview workers to determine how the hiring process worked.

(4) Ask how child workers are housed, and how the housing was arranged.

(5) Ask what steps, if any, a child worker must take to terminate his or her

employment. Ask if they know of child workers who have terminated

their employment contracts before the contract period ended.

(6) Ask if workers are required to turn over their identity papers to

management and if so, how, if at all, are they able to obtain the return of

their documents.

(7) Use indirect methods to verify workers ages, such as asking workers

the year they were born, how old their siblings are, or, in appropriate

regions, what “year” (year of the Dog, etc.) they were born. These and

similar techniques may produce accurate information from child workers

coached to state a false age.

(8) Ask what documentation workers were asked to show concerning their

age. This may provide a useful check against management’s statement

that it seeks reliable age verification.

(9) Ask whether management restricts the nature and amount of work

performed by employees under 18 years old.

(10) Ask workers under 18 if they are restricted in the nature and amount of

work they are allowed to do.

III. Interview Management

(1) Ask how workers arranged for terms of employment.

(2) Determine if side agreements require payments that violate these

provisions.

(3) Determine how the hiring process works, and if there are any agreements

with hiring or recruiting agents. In some industries in developing

countries, unscrupulous agents often recruit or even kidnap children to

work away from home as a source of cheap labor.

(4) If migrant labor is used locally, check whether contract terms limit child

workers’ ability to leave their jobs before their contract expires.

(5) Ask management what steps, if any, child workers must take to terminate

their employment. Ask management if any child workers have terminated
19

their employment contracts before their term ended. Ask to see any

records of workers who have done so, to verify the practice and make

sure that the child’s ability to terminate employment is not inappropriately

restricted.

(6) Ask managers and line supervisors how hiring, assignment, promotion,

and compensation decisions are made. Greater objectivity in making

such decisions indicates the work situation is less likely involving forced

or indentured labor. If managers and supervisors cannot answer fully,

subjective decision-making that can be used to further coercion may be

present.

(7) Ask how workers obtain housing.

(8) Ask management how, if at all, child workers can obtain return of their

identification papers, if management restrains them.

(9) Check to make sure that management is familiar with and understands

applicable child labor regulations, particularly restrictions on young

workers.

(10) Ask relevant management to explain factory procedures for verifying

workers’ ages.

(11) Ask whether and how management tries to restrict the nature and amount

of work performed by employees under 18 years old.

(12) Examine documentation and monitoring practices pertaining to wages

and benefits to check for non-payment or under-payment of wages and

benefits.

(13) Review all labor contracts to ensure compliance with wages and benefits

provisions.

(14) Review payroll to determine that advances are not paid or withheld in

ways that indicate forced or indentured child labor.

(15) Review records to verify that, if the law requires government permits or

permission from parents as a condition of employment, employers keep

all such documentation on-site for inspection at all times.

(16) Verify that personnel records of all child workers contain the most reliable

proof of age documentation available, such as a birth certificate, to

verify date of birth. If the factory is located in a region or country where

government documentation is not readily available or reliable, other

means, such as medical or religious records, could be used.
20

(17) Where reliable public proof of age documentation is not readily available,

determine whether other means of verifying age are used, such as letters

from parents, teachers or other known community members, attesting

to the individual’s age.

(18) Review documentation of any apprenticeship or job training programs

to ensure that participants are not below the appropriate age.

IV. Capacity Review

Fundamental questions posed in a capacity review include: (i) Does the factory have the

ability to produce final (completely constructed) product in the quantities booked or scheduled?

(ii) Has the factory performed all operations for work shipped in the period under review? If

the answer to either of these questions is no, it may be necessary to confirm that work

performed elsewhere is not performed by forced or indentured child labor.

V. Visual Inspection

(1) Observe factory entrances, docks, warehouses and dormitories,

particularly at shift changes, to determine if child workers are moved or

goods transported to secondary locations. The necessity for surveillance

should normally be left to the judgement of the monitor or monitoring

team.

(2) Observe and identify any employees who appear to be very young and

follow-up through an appropriate combination of interviews and record

review to determine proof of age and whether the individual is subject

to forced or indentured child labor.

(3) Identify groups of machines or workstations that are not staffed or are

only partially staffed. Ask other workers the names of people who

normally work at these stations and their descriptions. Check their

personnel files.

(4) If there are any child care or apprenticeship facilities near the factory,

observe if any underage persons linked to those facilities are near or

present in the factory.

(5) Determine if there are areas, operations and functions in the factory that

are considered hazardous for workers under 18.
21

APPENDIX D

 LIST OF CUSTOMS’ ATTACHÉS

BANGKOK, THAILAND

Bhutan, India, Kampuchea (Cambodia), Laos, Maldive Islands, Myanmar (Burma), Nepal, Sri Lanka,

Thailand, Vietnam

OFFICE PHONE: 011-66-2-205-5015

AMEMBASSY PHONE: 011-66-2-205-4000

FAX 011-66-2-253-4448

OFFICE ADDRESS: AMEMBASSY

120 WIRELESS RD.

BANGKOK, THAILAND

MAILING ADDRESS: CUSTOMS ATTACHE

C/O AMERICAN EMBASSY, BOX 5

APO AP 96546

BEIJING, CHINA

Mongolia, The People’s Republic of China (PRC)

OFFICE PHONE: 011-86-10-6500-3012

FAX: 011-86-10-6500-3032

OFFICE ADDRESS: AMEMBASSY

XIU SHUI BEI JIE 3

BEIJING, PEOPLES REPUBLIC OF CHINA, 100600

MAILING ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY, BEIJING

DEPARTMENT OF STATE

WASHINGTON, D.C. 20521-7300

BERLIN, GERMANY

Armenia, Azerbaijan, Byelorussia, Commonwealth of Independent States, Denmark, Estonia, Faroe Islands,

Finland, Germany, Georgia, Greenland, Kazakhstan, Kirghiz, Latvia, Lithuania, Moldavia, Norway, Poland,

Sweden, Tajik (Tadzhik), Turkmen, Ukraine, Uzbek

OFFICE PHONE: 011-49-30-8305-1470

FAX: 011-49-30-8322-9905

OFFICE ADDRESS: AMERICAN EMBASSY

CUSTOMS ATTACHE/BERLIN (USCS)

CLAYALLE 170

14195 BERLIN

MAILING ADDRESS: CUSTOMS ATTACHE

AMEMBASSY – BERLIN

PSC 120 BOX 3000

APO AE 09265

GERMANY
22

BOGOTA, COLOMBIA

OFFICE PHONE: 011-571-315-2162

FAX: 011-571-315-2153

OFFICE ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY

CARRERA 45# 22D

SANTAFE DE BOGOTA, COLOMBIA

MAILING ADDRESS: AMERICAN EMBASSY

CUSTOMS ATTACHE

UNIT 5116

APO AA 34038

BRUSSELS, BELGIUM

OFFICE PHONE: 011-322-209-9334

FAX: 011-322-209-9495

OFFICE ADDRESS: U.S. MISSION TO THE EUROPEAN COMMUNITIES

40 BLVD. DU REGENT

B-1000

BRUSSELS, BELGIUM

MAILING ADDRESS: USEC – ENFORCEMENT REPRESENTATIVE

WORLD CUSTOMS ORGANIZATION

PCS 82, BOX 2

APO AE 09724

CARACAS, VENEZUELA

Colombia, Ecuador, French Guiana, Guyana, Peru, Suriname, Venezuela

OFFICE PHONE: 011-58-2-975-9110

AMEMBASSY 011-58-2-975-2011

FAX: 011-58-2-975-6556

OFFICE ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY

CALLE B CON CALLE F

COLINAS DE VALLE ARRIBA

CARACAS, VENEZUELA

MAILING ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY

UNIT 4964

APO AA 34037
23

FRANKFURT, GERMANY

Germany

OFFICE PHONES: 011-49-69-7535-3630

CONSULATE/CG 24 HRS 011-49-69-7535-0

FAX: 011-49-69-7535-3601

OFFICE ADDRESS: U.S. CUSTOMS SERVICE

AMERICAN CONSULATE

PLATENSTRASSE 9

60320 FRANKFURT AM MAIN

MAILING ADDRESS: U.S. CUSTOMS SERVICE

PSC-115 U.S. CUSTOMS

APO AE 09213

HERMOSILLO, MEXICO

Mexico States of: Durango, Chihuahua, Njayarit, Sinaloa, Sonora

OFFICE PHONE: 011-52-62-12-39-71

FAX: 011-52-62-17-40-34

OFFICE ADDRESS: SENIOR CUSTOMS REPRESENTATIVE

C/O AMERICAN CONSULATE GENERAL

MONTERRY 141 PONIENTE

HERMOSILLO, SONORA, MEXICO

MAILING ADRRESS: C/O AMERICAN CONSULATE GENERAL

P.O. BOX 3598

LAREDO, TEXAS 78044-358

HONG KONG

Afghanistan, Macau, Hong Kong, Pakistan, Phillipines, Taiwan (ROC)

OFFICE PHONE: 011-852-2524-2267

EMB/CG 24 HRS: 011-852-2523-9011

FAX: 011-852-2810-6550

OFFICE ADDRESS: AMERICAN CONSULATE GENERAL

26 GARDEN RD.-ROOM 221

CENTRAL

HONG KONG

MAILING ADDRESS: SENIOR CUSTOMS REPRESENTATIVE

AMERICAN CONSULATE GENERAL

PSC 461, BOX 15

FPO AP 96521-0006
24

INTERPOL, LYON, FRANCE

OFFICE PHONE: 011-334-7244-7185

FAX: 011-334-7244-7321

CONSULATE: 011-334-7244-7000

MAILING ADDRESS: AMERICAN EMBASSY PARIS (INTERPOL)

PSC 116

APO AE 09777

LONDON, ENGLAND

Channel Islands, Gibraltar, Iceland, Ireland, Northern Ireland, United Kingdom

OFFICE PHONE: 011-44-207-493-4599

EMBASSY 24 HR: 011-44-207-499-9000

OFFICE ADDRESS: AMEMBASSY

24/31 GROSVENOR SQUARE

LONDON W1A 1AE

UNITED KINGDOM

MAILING ADDRESS: CUSTOMS ATTACHE

C/O AMERICAN EMBASSY

PSC 801 BOX 52

FPO AE 09498-4052

MEXICO CITY, MEXICO

Mexico States of: Colima, Distrito Federal, Guerrero, Guanajuato, Hidalgo, Jalisco, Mexico, Michoacan,

Morelos Oaxaca, puebla, Queretaro, Tiaxcala, Queretaro, Campeche, Chiapas, Vera Cruz, Quintana Roo,

Tabasco and Yucatan

OFFICE PHONE: 011-525-209-9100 EXT. 3688

FAX: 011-525-525-5977

OFFICE ADDRESS: AMEMBASSY

PASEO DE LA REFORMA 305

COLINA CUAUHTEMOC 06500

MEXICO, D.F., MEXICO

MAILING ADDRESS: CUSTOMS ATTACHE

C/O AMEMBASSY

P.O. BOX 3087

LAREDO, TEXAS 78044

MONTERREY, MEXICO

Mexican States of: Aguascalientes, Coahuila, San Luis Potosi, Tamaulipas, Nuevo Leon, Zacatecas

OFFICE PHONE: 011-52-8-342-7972

CONSULATE 24 HR: 011-52-8-345-2120

FAX: 011-52-8-343-2708

OFFICE ADDRESS: SENIOR CUSTOMS REPRESENTATIVE

CONSULADO GENERAL AMERICANO

AVE. CONSTITUCION 411 PTE.

MONTERREY, N.L., MEXICO 64630
25

MAILING ADDRESS: SENIOR CUSTOMS REPRESENTATIVE

C/O AMERICAN CONSULATE-MONTERREY

P.O. BOX 3098

LAREDO, TEXAS 78044-3098

MONTEVIDEO, URUGUAY

Chile, Uruguay, Paraguay, Argentina, Brazil, Bolivia

OFFICE PHONE: 011-598-2-411-1835

011-598-2-411-1837

EMBASSY SWITCHBOARD: 011-598-2-203-6061

EMBASSY 24 HR: 011-598-2-401-8888

FAX: 011-598-2-411-8138

MAILING ADDRESS: U.S. CUSTOMS SERVICE

U.S. EMBASSY – MONTEVIDEO

UNIT 4520

APO AA 34035

OFFICE ADDRESS: U.S. EMBASSY

LAURO MULLER 1776

MONTEVIDEO, URUGUAY

MOSCOW, RUSSIA

Russia

OFFICE PHONE: 011-7-095-728-5050

FAX: 011-7-095-728-5140

OFFICE ADDRESS: AMERICAN EMBASSY

19-23 NOVINSKY BLVD.

MOSCOW, 121099, RUSSIA

MAILING ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY/MOSCOW

PSC 77 – U.S. CUSTOMS

APO AE 09721

*** If mailing DHL, please mail to address below:

U.S. Customs Attache

American Embassy Moscow

8 Bolshoi Devyatinsky Pereulok

121099 Russia, Moscow
26

OTTAWA, CANADA

OFFICE PHONE: 1-613-230-2120

FAX: 1-613-238-1855

MAILING ADDRESS: CUSTOMS ATTACHE

C/O AMEMBASSY

P.O. BOX 5000 – MS – 45

OGENSBURG, NY

13669-0430

OFFICE ADDRESS: U.S. CUSTOMS SERVICE

490 SUSSEX DRIVE

OTTAWA, ONTARIO

K1N 1G8

FED EX ADDRESS: U.S. CUSTOMS SERVICE

AMERICAN EMBASSY

207 BANK STREET

SUITE 249

OTTAWA, ONTARIO

K2P 2N2

PANAMA CITY, PANAMA

Panama

OFFICE PHONE: 011-507-225-7562

EMBASSY SWITCHBOARD: 011-507-207-7000

EMBASSY AFTER HOURS: 011-507-207-7000

FAX: 011-507-227-2117

OFFICE ADDRESS: CALLE 38 AND AVENIDA BALBOA

PANAMA CITY, PANAMA

MAILING ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY

UNIT 0945

APO AA 34002

PARIS, FRANCE

France, Belgium, Spain, Portugal, Algeria, Morocco, Morocco, Mauritania, Mali, Niger, Benin, Togo, Ghana,

Nigeria, Ivory Coast, Liberia, St. Helena, Sierra Leone, Guinea, Guineau-Bissau, Gambia, Senegal, Monaco,

Cape Verde, Andorra, Western Sahara, Sao Tome’ & Principe, Luxembourg, Burkina Faso (Upper Volta)

OFFICE PHONE: 011-331-4312-7400

EMBASSY SWITCHBOARD: 011-331-4312-2222

FAX: 011-331-4562-3639

OFFICE ADDRESS: AMEMBASSY

58 BIS RUE LA BOETIE

ROOM 317

75008 PARIS, FRANCE
27

MAILING ADDRESS: AMEMBASSY PARIS (CUSTOMS ATTACHE)

PSC 116 (RM D-317)

APO AE 09777

PRETORIA, SOUTH AFRICA

Botswana, Lesotho, Madagascar (Malagasy Republic), Mauritius, Mozambique, Namibia, South Africa,

Swaziland, Comoros Islands, Zimbabwe, Seychelles

OFFICE PHONE: 011-27-12-342-8062

EMBASSY SWITCHBOARD: 011-27-12-342-1048 EXT. 3044

FAX: 011-27-12-342-7097

OFFICE ADDRESS: AMEMBASSY

877 PRETORIUS

ARCADIA, PRETORIA 001

SOUTH AFRICA

U.S. MAILING ADDRESS: AMEMBASSY PRETORIA

DOS-EMBASSY CUSTOMS

9300 PRETORIA PLACE

WASHINGTON, D.C. 20521-9300

INTERNATIONAL MAILING: AMEMBASSY PRETORIA

P.O. BOX 9536

PRETORIA 0001

SOUTH AFRICA

ROME, ITALY

Albania, Angola, Bahrain, Burundi, Cameroon, Central African Republic, Chad, Congo, Cyprus, Democratic

Republic of the Congo, Djibouti, Egypt, Equatorial Guinea, Eritrea, Ethiopia, Gabon, Greece, Iran, Iraq,

Israel, Italy, Jordan, Kenya, Kuwait, Lebanon, Libya, Malawi, Malta, Oman, Qatar, Republic of San Marino,

Rwanda, Saudi Arabia, Somalia, Sudan, Syria, Tanzania, Tunisia, Turkey, Uganda, United Arab Emirates,

Vatican City, Yemen, Zambia

OFFICE PHONE: 011-39-06-4674-2475

EMB/SWITCHBOARD: 011-39-06-46741

FAX: 011-39-06-4674-2351

OFFICE ADDRESS: AMERICAN EMBASSY

VIA VENETO 119/A

00187 ROME, ITALY

MAILING ADDRESS: CUSTOMS ATTACHE

PSC 59 BOX 19

APO AE 09624
28

SEOUL, KOREA

South Korea (ROK), North Korea (DPRK)

OFFICE PHONE: 011-822-397-4644

011-822-397-4232

FAX: 011-822-736-6850

OFFICE ADDRESS: AMEMBASSY

82 SEJONG-RO

CHONGRO-KU

SEOUL, KOREA

110-050

MAILING ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY

UNIT 15550

APO AP 96205-0001

SINGAPORE

Singapore, Malaysia, Brunei, Indonesia, East Timor, Bangladesh, Christmas Is., Papua New Guinea,

Australia, New Zealand, Nauru, Solomon Is., New Caledonia, Cook Is., Tokelau, Vanuatu, Niue, Federated

States of Micronesia

OFFICE PHONE: 011-65-476-9020

EMBASSY 24 HR: 011-65-476-9100

FAX: 011-65-476-9188

OFFICE ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY

27 NAPIER ROAD

SINGAPORE 258508

MAILING ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY

PSC 470, BOX – CUSTOMS

FPO AP 96507

TIJUANA, MEXICO

OFFICE PHONE: 011-52-66-817-7400 EXT. 320

FAX: 011-52-66-817-7206

OFFICE ADDRESS: US CUSTOMS SERVICE

185 W. “F” STREET, SUITE 600

SAN DIEGO, CA 92101

MAILING ADDRESS: US CONSULAR GENERAL

P.O. BOX 439-039

SAN DIEGO, CA 92143
29

TOKYO, JAPAN

Japan, and Ryukyu Island (Okinawa)

OFFICE PHONE: 011-813-3224-5433

24 HR OPERATOR: 011-813-3224-5000

FAX: 011-813-3224-5426

OFFICE ADDRESS: CUSTOMS ATTACHE

AMEMBASSY

10-5, AKASAKA 1-CHOME

MINATO-KU, TOKYO, 107-8420 JAPAN

MAILING ADDRESS: CUSTOMS ATTACHE

AMERICAN EMBASSY, TOKYO

UNIT 45004, P.O. BOX 221

APO AP 96337-5004

VIENNA, AUSTRIA

Austria, Switzerland, Liechtenstein, Romania, Czech Republic, Slovakia, Hungary, Bulgaria, Slovenia,

Macedonia, Bosnia-Herzegovina, Yugoslavia, Croatia

OFFICE PHONE: 011-43-1-313-39-2112

EMB/SWITCHBOARD: 011-43-1-313-39

EMB/CG 24 HRS: 011-43-1-313-39-2320

FAX: 011-43-1-313-39-2430

OFFICE ADDRESS: AMERICAN EMBASSY

BOLTZMANNGASSE 16

A-1091 VIENNA, AUSTRIA

MAILING ADDRESS: CUSTOMS ATTACHE

DOS/EMBASSY/CUSTOMS

9900 VIENNA PLACE

WASHINGTON, D.C. 20521-9900
U.S. CUSTOMS SERVICE

U.S. Customs Hot Line 1-800-BE ALERT

www.customs.gov