CBP has issued WROs against specific Malaysian palm oil producers and their subsidiaries under 19 U.S.C. § 1307, which prohibits importation of goods made with forced labor. Importers sourcing Malaysian CPO must conduct supplier-level due diligence — including social audits and supply-chain mapping — to confirm their specific supplier is not subject to an active WRO. Shipments from a WRO-listed entity will be detained at the port of entry regardless of the tariff classification.

CPO imported in crude form is almost always destined for further processing — refining, bleaching, and deodorizing (RBD) — before use in food products such as shortenings, margarines, and confectionery coatings, or in oleochemical and biofuel applications. Importers should document the intended downstream use, as this affects both FDA admissibility treatment and any applicable state-level environmental or biofuel regulations.