On January 14, 2025, the Department of Homeland Security (DHS) announced the addition of 37 China-based entities to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. DHS cited these entities’ alleged connections to sourcing material and forced labor in the Xinjiang Uyghur Autonomous Region (XUAR) as reasons for their addition.
This batch of entities represents the largest addition to the UFLPA Entity List so far, and it brings the total number of entities on the list to 144. The Biden administration signed the UFPLA into law in 2021. UFLPA established a rebuttable presumption that prohibits goods made in whole or in part in the XUAR from entering the U.S. To date, U.S. Customs and Border Protection (CBP) has reviewed over 12,600 shipments under UFLPA, with an estimated value of $3.68 billion.
Of the 37 newly added entities, 26 entities come from the cotton sector. These 26 entities comprise of Huafu Fashion Co., one of the largest textile manufacturers in the world, and 25 of its subsidiaries. The additions also include Zijin Mining Group Co., a large supplier of critical minerals, and its subsidiaries. The remaining added entities comprise of companies in the solar energy industry and suppliers that allegedly source polysilicon from the Xinjiang region.
The additions to the list are effective January 15, 2025.
Crowell & Moring, LLP continues to monitor developments in the customs and trade remedies space and their potential impact on businesses and customers going forward.