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  • Enforcement of the US Uyghur Forced Labor Prevention Act (UFLPA) in the first six months of FY2026 reflects a shift in both sector focus and enforcement outcomes. 
  • This alert analyses enforcement trends in FY2026 to date, from October 2025 to March 2026, with a focus on implications for the garment sector, based on data from the US Customs and Border Protection (CBP) statistics.

GENERAL TRENDS

  • Consumer products is now the most impacted sector, accounting for approximately 34% of detentions, followed by apparel at around 22%.
  • The automotive and aerospace sector is no longer a key focus of enforcement, with a sharp decline from approximately 59% of all detentions in 2025 to around 11% in FY2026 year-to-date.
  • Release rates have increased significantly across sectors, with approximately 60% of shipments released in FY2026 year-to-date compared to only around 23% in 2025.

APPAREL SECTOR

  • Release rates in the apparel sector have improved slightly, with approximately 47% of shipments released compared to around 41% in 2025. Cambodia saw a notable improvement, from approximately 10% of shipments released in 2025 to around 50% in 2026 year-to-date.
  • China continues to dominate apparel detentions, accounting for approximately 76% of shipments detained. Cambodia (~9%), Vietnam (~7%), Nicaragua (~2%) and Indonesia (~2%) follow.
  • Enforcement against Bangladesh has declined significantly, accounting for les than 1% of detentions in 2026 compared to around 7% in 2025.
  • A wide range of additional countries are minimally targeted, each accounting for less than 1% of detentions. These include Italy, the Philippines, Sri Lanka, Turkey, France, Germany, Mauritius, the United States, Cyprus, Denmark, Pakistan, Peru, Portugal, Slovakia, Spain, Taiwan and Thailand.
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