The Uyghur Forced Labor Prevention Act (UFLPA) is a U.S. law that bars goods made wholly or in part with forced labor in the Xinjiang Uyghur Autonomous Region (XUAR) of China from entering the United States. It creates a rebuttable presumption that such goods are made with forced labor and are therefore prohibited under Section 307 of the Tariff Act of 1930 (19 U.S.C. §1307).

When did the UFLPA take effect?

The UFLPA was signed into law on December 23, 2021, and its rebuttable presumption took effect on June 21, 2022. It is enforced by U.S. Customs and Border Protection (CBP) under policy set by the Forced Labor Enforcement Task Force (FLETF), which is chaired by the Department of Homeland Security.

What is the UFLPA Entity List?

The UFLPA Entity List is the consolidated list, maintained by the FLETF, of companies whose goods are subject to the rebuttable presumption — including entities operating in Xinjiang, those working with the regional government to recruit forced labor, and those sourcing material from the region. Goods linked to any listed entity are presumed barred from entry, regardless of where they were finished.

Who enforces the UFLPA?

U.S. Customs and Border Protection (CBP) enforces the UFLPA at the border by detaining shipments, while the Forced Labor Enforcement Task Force (FLETF), chaired by DHS, sets enforcement strategy and maintains the UFLPA Entity List.

What goods does the UFLPA apply to?

The UFLPA applies to any goods made "wholly or in part" in Xinjiang or by a listed entity — meaning even a single component or raw material sourced from the region can taint the entire finished product. It covers all merchandise, but CBP concentrates enforcement on designated high-priority sectors.

What are the high-priority sectors for UFLPA enforcement?

The original high-priority sectors are cotton and apparel, polysilicon and solar products, and tomatoes. CBP and the FLETF have since expanded enforcement attention to additional sectors including aluminum, polyvinyl chloride (PVC), and seafood. Goods in these sectors face heightened scrutiny and detention.

Does the UFLPA only apply to goods imported directly from China?

No. The UFLPA applies based on where the goods or their inputs were produced, not where they were shipped from. Products finished or transshipped through a third country — such as Vietnam, Malaysia, or Mexico — are still subject to the presumption if they contain Xinjiang-origin inputs or involve a listed entity.

How do I rebut the UFLPA presumption?

To overcome the presumption, an importer must respond fully to CBP, demonstrate that it complied with the FLETF and CBP due-diligence and supply-chain-tracing guidance, and provide clear and convincing evidence that the goods were not made with forced labor. CBP must then grant an exception and report it to Congress. The standard is high and exceptions are rarely granted, so prevention through screening is far more reliable than rebuttal.

What happens if my shipment is detained under the UFLPA?

CBP issues a detention notice and the importer generally has about 30 days to respond (extensions may be requested). The importer must submit documentation tracing the supply chain back to raw materials and showing the goods are outside UFLPA scope. CBP then releases, excludes, or seizes the goods. Detentions commonly cause weeks or months of delay even when goods are ultimately released.

What documentation do I need for UFLPA compliance?

You need a complete, verifiable supply-chain map tracing each component and raw material to its origin, plus supporting transaction records: purchase orders, invoices, production records, bills of materials, mill and factory certificates, and proof of payment at each tier. CBP’s UFLPA operational guidance specifies the evidence expected to trace goods back to the raw-material level.

What is supply-chain tracing?

Supply-chain tracing (or mapping) is the process of documenting every tier of a product’s supply chain — from the finished good back through sub-assemblies, components, and raw materials — so you can prove none of it originates in Xinjiang or with a listed entity. It is the central evidentiary requirement for both preventing and responding to UFLPA detentions.

How do I screen suppliers for UFLPA risk?

Screen every supplier and their owners against the UFLPA Entity List and related restricted-party lists, map your supply chain to the raw-material tier, watch for Xinjiang nexus and known aliases, and re-screen continuously because the Entity List is updated over time. Continuous screening catches a new listing before your next shipment ships.

What is the difference between the UFLPA and a Withhold Release Order (WRO)?

Both enforce the forced-labor import ban in Section 307 (19 U.S.C. §1307). A Withhold Release Order is a targeted CBP order against specific merchandise or producers based on evidence of forced labor, where CBP carries the initial burden. The UFLPA is a statute that establishes a broad rebuttable presumption for Xinjiang-linked goods, shifting the burden onto the importer from the outset.

Is there a value threshold or de minimis exemption under the UFLPA?

No. The UFLPA applies regardless of shipment value, and there is no de minimis exemption. Even low-value shipments and small inputs are within scope if they have a Xinjiang nexus or involve a listed entity.

What are the consequences of a UFLPA violation?

Goods within UFLPA scope are detained and then excluded or seized, so the primary cost is the loss of the merchandise plus significant shipment delays and disrupted supply. Importers can also face reputational harm, and separate civil or criminal penalties may apply where there is fraud or material misstatement.

Who is responsible for UFLPA compliance?

The importer of record is responsible. As with classification and valuation, the obligation to exercise due diligence over the supply chain and to respond to CBP detentions falls on the IOR — even when a customs broker files the entry.

What law underlies the UFLPA?

The UFLPA (Public Law 117-78) builds on Section 307 of the Tariff Act of 1930, codified at 19 U.S.C. §1307, which prohibits importing goods made with forced labor. The UFLPA adds the rebuttable presumption specific to Xinjiang and listed entities, and directs the FLETF to maintain the strategy and Entity List.

How can importers reduce UFLPA risk?

Build a traced, documented supply chain to the raw-material level, screen all suppliers and their owners against the Entity List continuously, prefer suppliers who can provide origin certificates and audit access, and maintain evidence packages in advance so you can respond to a detention within CBP’s deadline. Prevention is far cheaper than fighting a detention.

Pillar guide

UFLPA compliance

Q: What is the UFLPA rebuttable presumption?

The rebuttable presumption is the core mechanism of the UFLPA: CBP presumes that any goods mined, produced, or manufactured wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are made with forced labor and are barred from entry. The burden flips to the importer to prove otherwise — the goods are detained unless the importer rebuts the presumption.

The Uyghur Forced Labor Prevention Act creates a rebuttable presumption that goods linked to Xinjiang are made with forced labor and barred from entry. This guide explains the presumption, the Entity List, what happens at detention, and how continuous screening keeps importers clear.

What is the UFLPA?

The Uyghur Forced Labor Prevention Act (UFLPA) bars goods made wholly or in part with forced labor in China’s Xinjiang region from entering the U.S. It builds on the long-standing forced-labor import ban in Section 307 of the Tariff Act of 1930 (19 U.S.C. §1307), adding a powerful new enforcement tool: the rebuttable presumption.

The rebuttable presumption

CBP presumes that any goods produced wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are made with forced labor and are prohibited. The burden is on the importer of record to rebut that presumption with clear and convincing evidence — a high bar that CBP rarely waives. The word “in part” matters: a single tainted input can bar an entire finished product.

High-priority sectors

The UFLPA applies to all merchandise, but enforcement concentrates on sectors with known Xinjiang exposure:

Cotton & apparel

Original high-priority sector

Polysilicon & solar

Modules, cells, ingots, wafers

Tomatoes

Including paste & processed products

Aluminum

Added enforcement focus

PVC

Added enforcement focus

Seafood

Added enforcement focus

What happens when CBP detains a shipment

A detention starts a tight clock. You must produce a supply-chain trace back to raw materials — fast — or the goods are excluded or seized:

1CBP issues a detention notice when goods are suspected of UFLPA scope.
2You typically have ~30 days to respond (extensions can be requested).
3Provide a full supply-chain trace back to raw materials, plus transaction records.
4CBP either releases the goods, excludes them, or seizes them.
5To overcome the presumption you must show clear and convincing evidence — a high, rarely-granted bar.

How importers stay clear

Because the presumption is so hard to rebut, prevention beats response. That means mapping your supply chain to the raw-material tier, collecting origin documentation in advance, and continuously screening every supplier and its owners against the UFLPA Entity List — which is updated over time, so a clean supplier today can be listed tomorrow.

Importer of Record →

The party responsible for UFLPA due diligence.

Customs Compliance →

How forced-labor rules fit the wider compliance picture.

HTS Code Lookup →

Identify high-priority-sector goods by their codes.

UFLPA frequently asked questions

Everything importers ask about the Uyghur Forced Labor Prevention Act and staying compliant, answered.

Catch UFLPA matches before CBP does

Tariffloop's AI customs compliance agent continuously screens every supplier you deal with against the UFLPA Entity List, OFAC, and BIS lists — even on aliases — so a new listing surfaces before your next shipment ships. Unsure of a term? Check the glossary.

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