CBP has issued Withhold Release Orders against specific palm oil producers and their derivatives based on forced labor findings under 19 U.S.C. § 1307. Importers of margarine or shortening containing palm oil must conduct supply-chain due diligence to confirm their palm oil does not originate from a listed entity; shipments linked to covered producers can be detained and excluded at the port of entry.

Margarine sold in the US must meet FDA's standard of identity, which specifies minimum fat content and permitted ingredients. Imported margarine must be labeled in English with a compliant Nutrition Facts panel, and the foreign manufacturer must be registered with FDA. Products that do not meet the standard of identity may be refused entry or require relabeling under FDA supervision.