Enforcement of the UFLPA remained mostly steady in 2024, with only a slight increase in the total number of shipments detained compared to 2023. In the apparel sector, China and Vietnam continued to account for most detentions. However, in 2024, CBP also started targeting Bangladesh and the Philippines. The clearance rate for detained apparel shipments remains lower than the overall average across sectors. This may be because importers are not able to provide sufficient evidence that their goods are not linked to XUAR or that they are choosing to re-export the goods to other markets.
- This alert includes an analysis of enforcement of the US Uyghur Forced Labor Prevention Act (UFLPA) in 2024 and key trends relevant to the garment sector. Our findings are based on a review of data from the US Customs and Border Protection (CBP) dashboard, which provides month-by-month enforcement data.
General trends
- In 2024, the number of detained shipments saw only a modest increase compared to 2023. In 2023 CBP detained 4,017 shipments and in 2024 this increased to 4,619.
- Enforcement against the electronics sector increased substantially in 2024. Electronics was already the most targeted sector in 2023 with 1460 detentions and accounting for 36% of all shipments detained. In 2024, detentions almost doubled to 2623, accounting for 56% of all shipments detained. Apparel (19% of shipments) and industrial and manufacturing materials (7% of shipments) were the next most targeted sectors.
- While China and Vietnam remained the most targeted countries, Thailand saw a sharp increase in detentions, rising from just 3% in 2023 to 18.5% in 2024. Nearly all detained shipments from Thailand (99%) were in the electronics sector.
- In 2024, a greater percentage of Chinese shipments were denied entry compared to the previous year, increasing from 44.6% in 2023 to 61.6% in 2024. Under the UFLPA, importers can provide evidence that their goods are not linked to XUAR to have their goods cleared. In the case of China, we have seen a lower rate of shipments being cleared after being detained in comparison to the previous year.
- Conversely, clearance rates for Vietnamese shipments improved significantly. In 2023, only 26% of detained Vietnamese shipments were released, whereas in 2024, the majority (76%) were successfully cleared. This implies that while CBP is still targeting Vietnamese imports, importers are successfully demonstrating that their goods are not linked to XUAR.
Apparel sector
- Apparel detentions increased by 11.6% in 2024, from 785 shipments in 2023 to 876 in 2024. This made apparel the second most targeted sector in 2024, surpassing Industrial and Manufacturing Materials.
- A significantly lower percentage of shipments are cleared in the apparel sector (36%) than the average across all sectors (58%). We do not know why this is the case. It may be because importers are choosing to export goods that are detained rather than try to clear the goods through the CBP process.
- The majority of shipments detained in the sector are still from China and Vietnam, however, the overall number of shipments detained from Vietnam decreased significantly in 2024 – from 321 in 2023 to 200 in 2024.
- Conversely, in 2024, CBP increased the detention of shipments from Bangladesh, which now accounts for 15% of all apparel detentions, making it the third most targeted country in the sector.
- Shipments from the Philippines were targeted for the first time in 2024, accounting for 9% of shipments detained in the sector. Nicaragua accounted for 5% of all detained shipments in the sector.