The US Department of Homeland Security (DHS) published its annual update to the UFLPA Strategy. DHS has added five new high priority sectors and signalled that additional sectors and entities will be named in 2025/26.
Key findings
- Since July 2024, DHS has added 78 new entities to the Uyghur Forced Labour Prevention Act (UFLPA) Entity List, bringing the total to 144. However, no new entities have been added under the Trump Administration. If a company imports a product that is linked to a company on the Entity List, CBP can detain or exclude it at the border.
- DHS will expand the Entity List in 2025/26, including through greater engagement with NGOs and the use of supply chain tracing technologies.
- The strategy names five new high priority sectors for enforcement: caustic soda, lithium, steel, jujubes/red dates and copper. These sectors will now be subject to heightened scrutiny at ports.
- Existing high-priority sectors will continue to be monitored. These include aluminium, apparel, cotton and cotton products, polyvinyl chloride, seafood, silica-based products (including polysilicon), and tomatoes.
- DHS also published new criteria to identify additional high-risk sectors in the future, which includes:
- Credible evidence of multiple entities with a high risk of using or facilitating forced labour
- Sectors designated by China for expansion in XUAR
- Production in XUAR represents 15% or more of the total production of the product in China.
- DHS noted that it had removed one company from the Entity List. In practice, this was more of a reclassification: Changji Esquel Textile Co. Ltd was taken off the list of companies producing goods with forced labour and moved to the list of companies that source from XUAR or have ties to the XUAR government. The effect is the same—Changji’s goods remain barred from entering the US.
- UFLPA enforcement significantly increased in the first half of 2025 due to increased enforcement in the automative sector. In contrast, the apparel sector experienced a slight decline in detentions and there are no notable changes in the agriculture sector.
Background
- UFLPA bans the import of goods produced in the Xinjiang Uyghur Autonomous Region (XUAR) to the US. The UFLPA does not have a de minimis exception. This means that any level of content/input produced in XUAR makes a product subject to the ban.
- The Act establishes an Entity List, of companies that the US believes to be located in XUAR or connected to the XUAR regional government or the state-owned Xinjiang Production and Construction Corps (XPCC). Products with linkages to the Entity List are presumed to be made with forced labour and can be seized at Port.
- The US Customs and Border Protection (CBP) is the main enforcement body for the UFLPA. CBP is empowered to detain, exclude or seize and forfeit shipments that it believes violate the UFLPA.