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Forced labor remains one of the most pressing human rights violations tied to modern global supply chains. To combat this, the United States enacted the Uyghur Forced Labor Prevention Act (UFLPA) a landmark law designed to block goods connected to forced labor in China’s Xinjiang Uyghur Autonomous Region (XUAR).
Since its enforcement began on June 21, 2022, the UFLPA has redefined how manufacturers, importers, and brands approach sourcing, traceability, and supplier accountability.
What Is the UFLPA?
The UFLPA was signed into law by President Joe Biden on December 23, 2021, after receiving bipartisan approval in Congress. Its goal is clear — to prohibit the importation of goods made wholly or partly with forced labor and to hold importers responsible for proving clean supply chains.
The law establishes a “rebuttable presumption”: any goods mined, produced, or manufactured in Xinjiang, or linked to a listed entity, are automatically presumed to involve forced labor. These goods are banned from entering the United States unless the importer can provide clear and convincing evidence to the contrary.
Beyond trade enforcement, the Act directs the U.S. State Department to support Uyghur refugees, fund civil society programs, and advance global human rights advocacy.
How the UFLPA Law Is Enforced
The U.S. Customs and Border Protection (CBP) is the lead enforcement agency, operating under the Department of Homeland Security (DHS) and in coordination with the Forced Labor Enforcement Task Force (FLETF).
CBP enforces the UFLPA through four primary mechanisms:
Rebuttable Presumption Enforcement Goods linked to Xinjiang or to a listed entity are detained or excluded unless the importer can prove that forced labor was not involved in any part of production.
UFLPA Entity List This DHS-maintained list identifies companies, factories, and intermediaries involved in, or benefiting from, forced labor programs. As of August 2025, it includes 144 Chinese entities, spanning sectors such as textiles, polysilicon, aluminium, seafood, copper, lithium, and steel.
High-Priority Sectors for Enforcement CBP and FLETF have expanded the scope of enforcement beyond traditional sectors like cotton and solar. The latest updates flag additional high-risk materials such as caustic soda, copper, lithium, red dates, and steel.
Shipment Screening and Detentions CBP uses AI-driven targeting and risk analytics to trace supply origins. Since 2022, it has reviewed over 16,000 shipments, worth nearly US $3.7 billion, under the UFLPA framework — with detentions increasing sharply across 2024 and 2025.
UFLPA Compliance Expectations for Companies
For global manufacturers and importers, compliance under the UFLPA demands complete transparency and traceability across every supplier and sub-tier. The burden of proof lies with the importer — and it’s heavy.
Businesses must demonstrate due diligence and retain detailed evidence showing their products are free of forced labor.
Practical compliance actions include:
- Supply-chain mapping: Identify every supplier down to Tier 4, tracing all raw materials to origin.
- Due diligence and risk assessments: Conduct regular supplier audits and human rights impact evaluations.
- Policy enforcement: Embed a formal Forced Labor Compliance Policy and supplier code of conduct.
- Contractual safeguards: Add clauses that prohibit Xinjiang-sourced materials, grant audit rights, and allow termination for non-compliance.
- Documentation: Maintain chain-of-custody records, wage and recruitment documentation, and third-party audit reports.
- Monitoring: Subscribe to UFLPA Entity List updates and use automated systems to flag supplier risks in real time.
- Training: Prepare procurement and logistics teams to respond rapidly to CBP detention notices with complete documentation.
Failure to maintain this level of traceability can result in seized shipments, monetary loss, and reputational damage.
UFLPA Enforcement Trends and Global Impact
In just three years, UFLPA enforcement has evolved from targeted actions to full-scale global coordination.
- 2022: Focused primarily on textiles, cotton, and solar panels.
- 2023: Expanded to electronics and polysilicon supply chains.
- 2024–2025: Added high-risk categories such as aluminium, seafood, copper, lithium, and steel.
The UFLPA has also triggered similar frameworks worldwide.
- The EU Forced Labour Regulation, expected to enter force in 2026, will introduce a comparable import prohibition model.
- Canada implemented its Fighting Against Forced Labour and Child Labour in Supply Chains Act in 2024.
- Australia is finalizing reforms to its Modern Slavery Act to include traceability and enforcement powers.
Together, these developments represent a global shift from voluntary corporate social responsibility to mandatory human rights due diligence (mHRDD).
UFLPA Common Challenges for Businesses
Despite clear legal expectations, companies continue to face serious obstacles:
- Limited visibility into sub-tier suppliers and raw material origins.
- Documentation fatigue from manual supplier surveys and fragmented data.
- Resistance from overseas suppliers who fear disclosing sensitive sourcing details.
- Lack of automation to track real-time regulatory updates or evidence changes.
These challenges make manual compliance unsustainable. Companies that fail to digitize their due diligence will struggle to keep up as enforcement accelerates.
How Acquis Compliance Helps
Acquis Compliance enables global manufacturers and importers to transform manual due diligence into automated, data-driven compliance.
Through AI-powered supplier intelligence and document automation, Acquis helps teams:
- Screen suppliers automatically against the official UFLPA Entity List and other forced-labor databases.
- Launch supplier declaration campaigns to capture detailed labor-practice and material-origin data.
- Digitally trace materials across BOMs with CAS-level precision.
- Generate “clear and convincing” documentation packs aligned with CBP expectations.
- Maintain real-time dashboards highlighting high-risk suppliers, products, and materials.
- Integrate directly with ERP and PLM systems for continuous risk visibility and audit readiness.
Whether managing 50 suppliers or 5,000, Acquis helps companies achieve true supply-chain transparency — and protect their brand integrity against forced labor risks.
Book a UFLPA Readiness Diagnostic
The Bottom Line
The UFLPA has evolved into one of the most consequential trade and human rights laws of this decade. By 2025, enforcement is no longer experimental — it’s operational, coordinated, and data-driven.
For businesses, compliance isn’t just about avoiding detentions; it’s about proving ethical governance in every sourcing decision. Those that invest in traceability, automation, and transparency today will not only stay compliant but also strengthen their position as trusted, responsible global manufacturers.
Key Official Resources
- DHS – UFLPA Strategy: https://www.dhs.gov/uflpa-strategy
- DHS – UFLPA Entity List: https://www.dhs.gov/uflpa-entity-list
- CBP – UFLPA Enforcement Statistics: https://www.cbp.gov/newsroom/stats/trade/uyghur-forced-labor-prevention-act-statistics
- Federal Register – Entity List Update (Dec 2023): https://www.federalregister.gov/documents/2023/12/11/2023-26984/notice-regarding-the-uyghur-forced-labor-prevention-act-entity-list