The Dark Side of Coffee: Forced Labor and Global Trade

Where Does Your Coffee Come From?

Nearly two-thirds of American adults drink coffee every day. For many of us, that morning cup is as routine as brushing our teeth. But how often do we stop and ask a simple question, ‘Where did this coffee come from, and how was it harvested?’

More importantly, could forced labor have played a role in getting those beans from the farm to your kitchen?

Recently, Mexican coffee producer Finca Monte Grande made headlines when U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against coffee harvested by the company. The allegation? The use of forced labor.

So what does that mean for your daily cup of coffee? Let’s break it down.

What Is Forced Labor?

Forced labor occurs when individuals are compelled to work against their will through force, fraud, or coercion. According to the International Labour Organization (ILO), forced labor is:

“All work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.”

While many people associate forced labor with historical events or distant parts of the world, it remains a very real problem today.

The ILO estimates that 27.6 million men, women, and children are trapped in forced labor globally across nearly every economic sector. Of those, approximately 4.9 million are victims of forced commercial sexual exploitation, while millions more are exploited in agriculture, manufacturing, fishing, mining, and other industries.

Forced labor is often fueled by poverty, discrimination, lack of economic opportunity, and weak labor protections. In many cases, workers are deceived about the nature of the job, trapped by debt, have their identity documents confiscated, or are threatened with violence or deportation if they attempt to leave.

The financial impact is staggering. The ILO estimates that forced labor generates approximately $236 billion in illegal profits every year. That’s $236 billion in wages and earnings that should have gone to workers, but instead ended up in the pockets of those exploiting them.

The Finca Monte Grande Case

Finca Monte Grande is a Mexican coffee producer whose beans enter the specialty coffee supply chain through various importers and roasters. Publicly available sourcing information does not clearly identify every downstream purchaser, making traceability difficult without disclosures from importers or coffee brands.

CBP’s investigation into Finca Monte Grande reviewed extensive evidence, and according to CBP, the evidence demonstrated the presence of six ILO indicators of forced labor:

Abuse of vulnerability, withholding of wages, retention of identity documents, excessive overtime, debt bondage, abusive working and living conditions

Based on this information, CBP determined there was reasonable suspicion that workers were subjected to forced labor and CBP issued a Withhold Release Order.

What Is a Withhold Release Order (WRO)?

A Withhold Release Order is one of CBP’s most powerful enforcement tools.

When CBP obtains information that reasonably indicates merchandise is being produced with forced labor, it can issue a WRO against the manufacturer or producer. Once issued, shipments covered by the order can be detained at U.S. ports of entry.

In practical terms, this means products linked to forced labor cannot enter the United States unless the importer can prove the goods were not produced with forced labor.

CBP’s message is clear, if a company profits from forced labor, it should not have access to the U.S. market.

Other Recent Forced Labor Actions

Finca Monte Grande is far from an isolated case.

In May 2025, CBP issued a WRO against the Chinese fishing vessel “Zhen Fa 7”, citing evidence of forced labor practices aboard the vessel. The order remains active.

Another example is “Taepyung Salt Farm”, one of South Korea’s largest sea salt producers. CBP issued a WRO against the company in April 2025 after identifying numerous ILO forced labor indicators, including:

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, excessive overtime

For many consumers, the idea that sea salt, seafood, or coffee could be connected to forced labor is surprising. But these cases demonstrate that forced labor risks exist across a wide range of industries and countries.

What Can Importers Do?

The answer is simple to say and can be much harder to execute “know your supply chain.”

Importers can no longer afford to stop their due diligence at the direct supplier level. Understanding where raw materials originate, who harvests them, who processes them, and under what conditions they are produced is becoming a fundamental business requirement.

CBP expects importers to exercise reasonable care and conduct meaningful supply chain due diligence. This includes evaluating suppliers, tracing sourcing locations, reviewing labor practices, and documenting compliance efforts.

One important resource is the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, which identifies entities linked to forced labor concerns in the Xinjiang Uyghur Autonomous Region of China.

The UFLPA, signed into law on December 23, 2021, established a rebuttable presumption that goods produced wholly or in part in Xinjiang are made with forced labor and are therefore prohibited from entering the United States unless the importer can demonstrate otherwise.

Much like export controls, forced labor compliance places responsibility squarely on the importer. CBP expects companies to know who they are doing business with and to understand the risks associated with their supply chains.

Build an Import Compliance Program Before CBP Builds One for You

As mentioned above, days of simply knowing your supplier are over. CBP increasingly expects importers to understand their entire supply chain, from the source of raw materials all the way to the labor conditions under which products are made.

A strong import compliance management program helps companies identify forced labor risks before shipments are detained, suppliers are added to enforcement lists, or customers start asking difficult questions. It creates a framework for supplier due diligence, supply chain mapping, risk assessments, documentation, and ongoing monitoring.

The reality is that most companies don’t intentionally source products connected to forced labor. However, good intentions won’t prevent a shipment from being detained at the border. CBP places the responsibility on the importer to know where products come from and to demonstrate compliance when questioned.

Whether you’re importing coffee, seafood, electronics, industrial components, or finished goods, now is the time to evaluate your compliance program and identify potential gaps before they become costly enforcement actions.

At Export Solutions, Inc., we help companies develop practical import compliance programs that stand up to regulatory scrutiny while supporting business growth. If you’re unsure whether your supply chain due diligence process is sufficient, let’s start with a free consultation.