A Stronger UFLPA: What the 2025 Strategy Update Means
On August 19, 2025, the Forced Labor Enforcement Task Force (FLETF), chaired by the U.S. Department of Homeland Security and including agencies such as the Departments of Labor, State, Treasury, Justice, and Commerce, released its annual update to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People's Republic of China. This update, mandated annually under the Uyghur Forced Labor Prevention Act (UFLPA), outlines expanded enforcement measures to prevent goods made with forced labor — especially in the Xinjiang Uyghur Autonomous Region (XUAR) — from entering the U.S. market. The UFLPA, enacted in December 2021 and implemented in June 2022, was designed to prevent the importation of goods mined, produced, or manufactured wholly or in part with forced labor in China. The law establishes a rebuttable presumption that all goods mined, produced, or manufactured wholly or in part in the XUAR, or produced by entities on the UFLPA Entity List, are presumed to be made with forced labor and are therefore banned from entry into the U.S. unless an importer can provide clear and convincing evidence to the contrary. This legal framework has become a cornerstone of U.S. efforts to eliminate forced labor from supply chains and promote accountability for ongoing human rights abuses against Uyghurs and other religious and ethnic minority groups in the XUAR. The 2025 strategy update reinforces the U.S. government's commitment to shielding global supply chains from forced labor — in particular, the state-sponsored forced labor of Uyghur and other minority groups in China's Xinjiang region. The administration's position is clear: ending forced labor is a moral, economic, and national security imperative, and keeping goods made with forced labor out of U.S. supply chains promotes American values while addressing unfair competition that endangers American prosperity.
The UFLPA Entity List has grown dramatically, with 78 new Chinese entities added over the past year, bringing the total to 144 companies now presumed to have ties to forced labor.
Over the past year, 78 new entities have been added to the UFLPA Entity List, raising the total to 144 entities. These organizations are now presumed to have links to forced labor and are barred from supplying goods into the U.S. unless clear and convincing proof counters that presumption. The Task Force added 78 new entities, removed one, and made three technical corrections, reflecting streamlined internal processes for identifying organizations involved in forced labor. The newly added companies span a wide array of industries, many of which align with the newly designated high-priority sectors. Agriculture and food processing accounted for approximately 33% of the new additions, ranging from canned goods to food additives. Textiles and apparel accounted for another approximately 33%, covering manufacturers of garments, yarns, and fabrics. Metals and mining accounted for approximately 20% of new additions, including copper, lithium, and steel producers critical to batteries and construction. Electronics producers — particularly those sourcing lithium, polysilicon, and rare earth materials for consumer electronics, EV batteries, and solar panels — were also prominently featured. The FLETF expects to continue expanding the Entity List. Goods produced by entities on the list are prohibited from importation into the United States unless the importer can demonstrate with clear and convincing evidence that the goods were not made with forced labor. The FLETF's expansion will increasingly focus on entities that involve more complex supply chain relationships, including those that export goods produced by XUAR entities that use forced labor, or that work with the XUAR government to recruit, transport, or receive forced labor of persecuted groups.
The 2025 update designates caustic soda, copper, jujubes (red dates), lithium, and steel as new high-priority enforcement sectors, reflecting growing concern about forced labor in critical industrial supply chains.
The Task Force identified five new high-priority sectors for enforcement: caustic soda, copper, jujubes (red dates), lithium, and steel. These join previously designated sectors including aluminum, apparel, cotton and cotton products, polyvinyl chloride (PVC), seafood, silica-based products (including polysilicon), and tomatoes and downstream products. The additions reflect growing concerns about forced labor in emerging supply chains, particularly those tied to industrial inputs and global food exports. The inclusion of sectors like lithium, copper, and steel — critical to clean energy, defense, and infrastructure — signals a deliberate effort to link national security, trade enforcement, and human rights into a cohesive trade policy. For example, steel is identified in multiple official Chinese government plans as essential to local economic development in Xinjiang and is a target for further resource exploitation, increasing state control and thus forced labor risk. Similarly, Xinjiang is home to expanding lithium reserves and government-backed plans to develop what authorities have described as a major lithium mining and extraction hub, with documented evidence of state-sponsored labor transfers in lithium-related industries. The 2025 FLETF Strategy update reflects a deliberate policy decision to prioritize upstream raw materials and critical minerals rather than focusing solely on finished goods. This strategic shift means that importers across automotive, electronics, clean energy, and construction sectors now face substantially heightened UFLPA scrutiny, even when their direct suppliers are not located in Xinjiang, because the raw material inputs may trace back to XUAR-linked entities.
CBP has detained over 16,700 shipments valued at nearly $3.7 billion since UFLPA took effect, and denial rates are rising — making rigorous supply chain due diligence more critical than ever.
CBP's enforcement efforts have been strong and surgical, targeting high-risk shipments while facilitating legitimate trade. Since the implementation of the rebuttable presumption in June 2022, CBP has reviewed more than 16,700 shipments valued at almost $3.7 billion, covering a broad range of products from apparel and automotive parts to chemicals, electronics, flooring, and solar panels. Of these, over 10,000 shipments valued at nearly $900 million were denied entry. In the first half of 2025 alone, CBP detained 6,636 shipments — surpassing the total of 4,619 detained throughout all of 2024 — with 82.8% of those detentions involving goods from China. The percentage of detained shipments that are later successfully cleared has decreased, indicating stricter enforcement and reduced opportunities to dispute CBP's findings. Staunch enforcement of the rebuttable presumption under UFLPA ensures that U.S. consumers and businesses are not unwittingly supporting exploitative practices. By adding more entities and sectors into enforcement scope, the update pressures importers to rigorously vet their supply chains, strengthening overall supply chain resilience. The FLETF has also strengthened its partnerships with NGOs, private-sector entities, and foreign government counterparts, holding biannual stakeholder meetings and sector-specific webinars to address compliance challenges. The Task Force has stated it will continue to expand the Entity List, monitor high-priority sectors, and strengthen partnerships to ensure supply chains remain free from forced labor. For importers, this means supply chain mapping, materials sourcing controls, and comprehensive traceability documentation are no longer optional — they are essential to avoiding costly detentions, protecting market access, and demonstrating good-faith compliance with U.S. law.
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