The US Department of Homeland Security (DHS) has expanded the list of products/sectors that are subject to a rebuttable presumption pf forced labour under the Uyghur Forced Labour Prevention Act (UFLPA). A rebuttable presumption means that goods made wholly or in part in China’s Xinjiang Uyghur Autonomous Region (XUAR) are assumed to be made with forced labor and may not be imported into the US unless the importer can provide evidence to confirm that the goods are not made with forced labour. Even companies not importing directly from China may have goods detained if the materials used to produce those goods in a second country are tied at any level to the XUAR or to specific entities or commodities associated with forced labor in China.
The original list of commodities subject to the UFLPA restrictions included designated apparel, cotton and cotton products, silica-based products including polysilicon, and tomatoes and downstream products. Last year aluminum, polyvinyl chloride, and seafood were added to the list. DHS has now added steel, copper, lithium, caustic soda, and red dates (jujubes) as well.
The updated strategy also notes that 78 entities have been added to the UFLPA Entity List over the past year, bringing the total to 144 in industry sectors such as agriculture, batteries, electronics, food additives, household appliances, nonferrous metals, plastics, and textiles. Products of these entities are subject to the UFLPA’s rebuttable presumption and therefore excluded from entry into the U.S. The updated DHS strategy, including the entity list, can be found here: 2025 Updates to UFLPA Strategy (High-Priority Sectors) Report.