On August 19, 2025, the U.S. Department of Homeland Security’s Forced Labor Enforcement Task Force (FLETF) updated its Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China under the Uyghur Forced Labor Prevention Act (UFLPA). The update highlights two primary areas:
- the Entity List has increased by 78 companies since the 2024 update, resulting in a total of 144 Chinese organizations whose products are presumptively prohibited from entering U.S. commerce; and
- the FLETF has designated additional high-priority enforcement sectors: caustic soda, copper, jujubes (red dates), lithium, and steel (in addition to aluminum, apparel, cotton and cotton products, polyvinyl chloride (PVC), seafood, silica-based products including polysilicon, tomatoes and downstream products).
The U.S. Department of Homeland Security reported that, as of August 1, 2025, U.S. Customs and Border Protection had detained more than 16,700 shipments, with a total declared value of approximately $3.7 billion, for inspection under the UFLPA’s rebuttable presumption. Of these, over 10,000 consignments, valued at nearly $900 million, were denied entry.
According to the U.S. Department of Homeland Security, the Trump administration “will continue to hold companies who use or facilitate modern-slavery accountable for their human rights violations by prohibiting their goods from access to our markets.”
The update reflects the current level of enforcement and the risks associated with goods linked to the Xinjiang Uyghur Autonomous Region or to entities on the Entity List. With the designation of new priority sectors, it is expected that the number of detentions will increase in 2025-2026 compared to the previous year. U.S. importers should ensure that supply-chain mapping, materials sourcing controls, and comprehensive traceability documentation are in place. These and other measures are necessary to avoid shipment holds and detentions, forced labor findings and penalties, and reputational risks. Companies that have not yet updated their forced-labor risk assessments and policies to include the newly designated sectors should do so promptly.