The Department of Homeland Security (DHS) announced the addition of 43 companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List on July 31, 2026, with the additions effective August 3. DHS also made technical name updates to two entities already on the list.
The expansion brings the UFLPA Entity List to 187 entities, a 30% increase and the largest single expansion since the UFLPA was enacted in December 2021.
For U.S. importers, the additions reinforce the importance of knowing not only direct suppliers, but also the companies involved further upstream in the production of raw materials, components, and finished goods.
Sectors Affected
The 43 newly listed companies operate across five sectors:
- Aluminum
- Apparel
- Copper
- Cotton
- Tomatoes and downstream tomato products
Importers sourcing products or materials within these sectors should review their supply chains for connections to the newly listed companies, including indirect relationships through upstream suppliers.
What the UFLPA Entity List Does
The UFLPA establishes a rebuttable presumption that goods mined, produced, or manufactured wholly or in part in China’s Xinjiang Uyghur Autonomous Region, or by an entity on the UFLPA Entity List, are made with forced labor and prohibited from entry into the United States under 19 U.S.C. § 1307.
U.S. Customs and Border Protection (CBP) enforces the presumption at the border.
When merchandise is detained under the UFLPA, importers may provide documentation demonstrating that the merchandise is outside the scope of the law. If the merchandise is subject to the UFLPA presumption, obtaining an exception requires clear and convincing evidence that the goods were not mined, produced, or manufactured wholly or in part with forced labor.
Because products can contain materials or components that pass through multiple suppliers before final assembly, UFLPA exposure can extend well beyond an importer’s direct supplier.
Enforcement Continues to Expand
The latest Entity List expansion signals continued federal scrutiny of supply chains connected to forced labor.
DHS has also expanded the industries receiving heightened attention under the UFLPA. In addition to established priority sectors, the Forced Labor Enforcement Task Force has designated caustic soda, copper, lithium, red dates, and steel as high-priority sectors for enforcement.
For importers, this means UFLPA compliance should not be viewed as limited to companies directly sourcing goods from Xinjiang or to industries historically associated with forced labor enforcement. Supply chain visibility and documentation are increasingly important across a broader range of products and industries.
What Importers Should Do
- Audit direct and indirect suppliers against the updated UFLPA Entity List. The rebuttable presumption can apply to goods mined, produced, or manufactured wholly or in part by a listed entity, making visibility beyond first-tier suppliers increasingly important.
- Review open purchase orders and in-transit shipments. Determine whether current shipments or upcoming imports have any direct or indirect connection to a newly listed entity.
- Strengthen supplier due diligence. Consider incorporating representations, warranties, sourcing disclosures, and audit rights related to forced labor, Xinjiang sourcing, and UFLPA Entity List status into supplier compliance programs.
- Maintain detailed supply chain documentation. Importers should be prepared to trace products and materials through multiple tiers of the supply chain if CBP questions the admissibility of a shipment.
- Consult trade counsel when necessary. Importers facing a UFLPA detention or considering a request for an exception should understand the significant evidentiary requirements before submitting documentation to CBP.
- Monitor the Entity List regularly. The list continues to expand, and a supplier that clears screening today could be added in a future update.
Need to Check Your Supply Chain Against the Updated List?
ASK Alba™: Alba’s trade compliance team can help importers evaluate supplier exposure, review supply chain documentation, and strengthen UFLPA due diligence procedures.
References
DHS: DHS Announces Addition of 43 Companies to UFLPA Entity List
