BACKGROUND

The Uyghur Forced Labor Prevention Act (UFLPA) was enacted on December 23, 2021, and implemented on June 22, 2022. The UFLPA was designed to prevent the importation of goods mined, produced, or manufactured wholly or in part with forced labor in China. The multi-agency Forced Labor Enforcement Task Force (FLETF) monitors and develops the UFLPA and U.S. Customs and Border Protection (CBP) enforces its regulations. The UFLPA relies on a rebuttable presumption that any goods, wares, articles, or merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of China, or produced by an entity on the Uyghur Forced Labor Prevention Act Entity List, were made with forced labor and as such, are prohibited from entering the United States. Since its implementation, CBP has examined more than 16,000 shipments, valued at almost $3.7 billion.

UPDATES

On August 19, 2025, the Forced Labor Enforcement Task Force (FLETF) released a major update to the Uyghur Forced Labor Prevention Act (UFLPA), marking a significant expansion of its enforcement strategy. This update introduced three key changes aimed at strengthening the U.S. government’s ability to prevent goods made with forced labor from entering the country.

First, FLETF broadened the scope of its high-priority sectors. Originally focused on tomatoes, polysilicon, cotton, aluminum, apparel, polyvinyl chloride, and seafood—industries with well-documented ties to forced labor in Xinjiang—the list now includes five additional sectors: caustic soda, copper, lithium, red dates (jujubes), and steel. These additions reflect growing concerns about forced labor in emerging supply chains, particularly those tied to industrial inputs and global food exports.

Second, the update reports substantial revisions FLETF made to the UFLPA Entity List over the past year, adding 78 new Chinese entities and removing one, bringing the total number of listed entities to 144. The more recently added companies span a wide array of industries, many of which align with the newly designated high-priority sectors. The most significant sectors targeted by the Entity List expansions were from: 

  • Agriculture & Food Processing, approximately 33% of the new additions came from this sector, from canned goods to food additives
  • Textiles & Apparel, approximately 33% of the new additions came from this sector, covering manufacturers of garments, yarns, and fabrics
  • Metals and mining, approximately 20% came from this sector, including copper, lithium, and steel producers critical to batteries and construction
  • Electronics, featuring producers of components for consumer electronics, EV batteries, and solar panels, especially those sourcing lithium, polysilicon, and rare earths

Finally, FLETF announced new efforts to deepen collaboration with private industry, non-governmental organizations, and international partners. This move underscores a broader commitment to transparency, accountability, and global coordination in combating forced labor.

ANALYSIS

After eight months of relying on tariffs as the primary tool to address international trade imbalances and trade practices it perceived as unfair, the Administration is expanding its arsenal with a renewed focus on UFLPA enforcement.  Expanding UFLPA enforcement reflects ongoing bipartisan interest in targeted trade actions that maximize the competitiveness of U.S. exports and promote U.S. standards by demanding improvements in supply chain visibility and vendor evaluation. The combination of tariffs and UFLPA expansion will increase the pressure to transform international trade behavior and drive systemic change in global supply chains.

The August 2025 strategy expansion suggests the administration is more fully integrating labor rights enforcement into its broader economic and geopolitical strategy, especially as it seeks to “de-risk” supply chains from reliance on China. The inclusion of sectors like lithium, copper, and steel—critical to clean energy, defense, and infrastructure—indicates a deliberate effort to link national security (a key element in the tariff strategy), trade enforcement, and human rights into a cohesive trade policy. Moreover, the continued focus on collaboration with private industry, international partners, and NGOs implies a shift to multilateral enforcement—building partnerships that efficiently seek and dismantle forced labor practices.

The FLETF message is clear: trade with the United States must be rooted not only in economic fairness but also in diligent supply chain management. As U.S. regulators continue to reshape the trade enforcement framework, stakeholders—from importers to compliance officers to foreign suppliers—should prepare for heightened scrutiny, dynamic enforcement, and greater demands for supply chain transparency.