Written by Julie Ann Parks, AAEI Chair Emeritus
The Department of Homeland Security (DHS), in coordination with the Forced Labor Enforcement Task Force, has released its 2025 update to the Uyghur Forced Labor Prevention Act (UFLPA) Strategy. This comprehensive report outlines the U.S. government’s intensified efforts to prevent goods produced with forced labor—particularly in China’s Xinjiang Uyghur Autonomous Region (XUAR)—from entering American markets.
Strategic Expansion and Enforcement
Since the enactment of UFLPA in 2021, DHS has led a multi-agency initiative to enforce Section 307 of the Tariff Act of 1930, which prohibits the importation of goods made with forced labor. The 2025 update reflects significant progress:
- Entity List Growth: The UFLPA Entity List has expanded from 20 to 144 entities, with 78 additions in the past year alone. These entities are linked to forced labor practices and are now subject to a rebuttable presumption barring their goods from U.S. entry.
- High-Priority Sectors: Five new sectors—caustic soda, lithium, steel, jujubes/red dates, and copper—have been added to the enforcement priority list. These join previously identified sectors such as aluminum, apparel, cotton and cotton products, polyvinyl chloride, seafood, silica-based products—including polysilicon—and tomatoes.
- Enforcement Metrics: From June 2022 to July 2025, U.S. Customs and Border Protection (CBP) detained 16,755 shipments valued at $3.69 billion. Of these, 10,274 were denied entry and 5,783 were released after review.
Global Coordination and Industry Impact
While the U.S. continues to engage international stakeholders, the report notes the absence of a unified global standard for forced labor enforcement. As a result, multinational companies must navigate a fragmented regulatory landscape. Notably, U.S. agencies have influenced multilateral development banks to require traceability to metallurgical-grade silicon in solar projects and to exclude sourcing from XUAR and listed entities.
Implications for Business Leaders
Executives should view this strategy update as a clear signal: supply chain transparency and due diligence are no longer optional. Companies operating in high-risk sectors must proactively audit sourcing practices and ensure compliance with UFLPA standards to avoid reputational and financial risk.
Call to Action for Customs & Trade Professionals
Trade and Supply Chain Professionals should:
- Reassess supplier relationships against the full Entity List and complete list of sectors
- Strengthen internal controls to ensure traceability
- Engage with industry peers and regulators to share best practices and stay ahead of enforcement trends
- Consider a mock detainment exercise to ensure documentation readiness
- Educate global partners on UFLPA requirements to reduce risk across the value chain
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