On April 2, 2025, the U.S. Customs and Border Protection (CBP), under the Department of Homeland Security, issued a Withhold Release Order (WRO) on sea salt exported by Taepyeong Salt Farm, determining that the product had been produced using forced labor. This marks the first instance of a Korean company’s goods being banned from import into the United States on the grounds of forced labor.
According to the CBP, its investigation found evidence of forced labor practices in the production of sea salt at Taepyeong Salt Farm, 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, and excessive overtime.” These are most of the indicators of forced labor as defined by the International Labour Organization Forced Labour Convention (No. 29).
Taepyeong Salt Farm is the single largest producer of sea salt in Korea, accounting for approximately 6% of the nation’s annual sea salt production. It not only sells its own branded salt products but also supplies salt to major food companies in the country. Located on Jeungdo Island in Sinan County, Taepyeong Salt Farm leases out most of its salt fields to multiple contractors, to whom it entrusts the production of sea salt. Repeated cases of forced labor involving persons with intellectual disabilities have occurred at these contracted sites.
The issuance of the WRO is a result of the Korean government and corporations’ longstanding failure to properly address or prevent forced labor at salt farms over the past decade. Since forced labor at salt farms—often referred to as “salt farm slavery”—first gained public attention in 2014, only one of the prosecuted perpetrators has been criminally punished under the Labor Standards Act’s prohibition of forced labor. The sentence was merely one year and two months of imprisonment.
Survivors with intellectual disabilities, after being rescued, frequently returned to salt farms due to the absence of a rehabilitation and reintegration system. Survivors who waited in vain for state support have passed away one by one. Meanwhile, companies that profited from the sale of salt produced through forced labor have continued to enjoy profits without any accountability.
Under the WRO, salt produced and exported by Taepyeong Salt Farm is now subject to seizure and cannot be distributed within the U.S. unless proven to be free from forced labor. Late last year, the EU Regulation on Prohibiting Products Made with Forced Labour on the Union Market (the “Regulation” or “FLR”) entered into force, and similar laws are already in place in Mexico and Canada. Companies will find it increasingly difficult to export products produced by forced labor.
We, civil society organizations working to introduce and enforce import bans against goods made using forced labour, welcome the CBP’s issuance of the Withhold Release Order and urge the Korean government to take proactive and immediate steps to eradicate forced labor. The government must revise its domestic laws, including the Anti-Trafficking Act to include explicit provisions criminalizing human trafficking and provide a clearer legal definition of forced labor. Furthermore, the government should establish reintegration support systems—such as employment and housing assistance—to ensure that survivors of forced labor, especially people with disabilities exploited on salt farms, are not returned to the same exploitative environments.
At the same time, Taepyeong Salt Farm and food companies that source sea salt must conduct human rights due diligence and take active measures to ensure that forced labor is eliminated from their supply chains.
Furthermore, import bans on forced labor products in other jurisdictions are not only to prevent unfair competition, but also to prevent citizens from indirectly contributing to forced labor by consuming goods produced by forced labor. South Korea should join the global effort to end forced labor by enacting legislation to ban the importation of forced labor.
April 7, 2025
Advocates for Public Interest Law (APIL)
Research Institute for the Differently Abled Person’s Rights in Korea
Wongok Law Firm