UFLPA

Supplier & Contractor Management

Uyghur Forced Labor Prevention Act

CBP Stopped 16,700+ Shipments Under UFLPA. Can You Prove Your Supply Chain Is Clean?

UFLPA compliance requires origin traceability to the raw material level—with "clear and convincing evidence" demanded to release detained goods. The Entity List now includes 144 entities. High-priority sectors expanded to 12 categories in 2025. Denial rates for China-origin shipments hit 77%. Certivo automates UFLPA supply chain tracing from supplier origin declarations to CBP-ready evidence packages.

Key Statistics

• 144: Entities on the UFLPA Entity List (2025)
• 16,700+: Shipments stopped by CBP since enforcement began
• 77%: Denial rate for China-origin detained shipments (FY 2025)

Regulation Overview

• Jurisdiction: United States (applies to all goods imported into the U.S.)
• Regulatory Body: U.S. Customs and Border Protection (CBP) / Forced Labor Enforcement Task Force (FLETF)
• Regulation Number: Public Law No. 117-78 (22 U.S.C. §6901 note)
• Effective Date: Enacted December 23, 2021; rebuttable presumption effective June 21, 2022
• Official Source: CBP Official Site
• Key Threshold: Rebuttable presumption: all goods from Xinjiang or Entity List entities are presumed prohibited

What is UFLPA?

The Uyghur Forced Labor Prevention Act is the primary U.S. law prohibiting imports of goods produced with forced labor connected to China's Xinjiang Uyghur Autonomous Region. For supply chain and compliance teams, UFLPA creates a rebuttable presumption that any goods mined, produced, or manufactured wholly or in part in Xinjiang—or by any entity on the UFLPA Entity List—are prohibited from U.S. importation.

Key Components / Sub-Frameworks

• Obligation: Importer must prove otherwise with "clear and convincing evidence"
• Rebuttable Presumption: All Xinjiang-origin or Entity List goods presumed made with forced labor
• UFLPA Entity List: 144 entities identified as using or facilitating forced labor
• High-Priority Sectors: 12 sectors including cotton, polysilicon, steel, copper, lithium, aluminum
• Section 307 (Tariff Act): Underlying prohibition on forced labor goods (19 U.S.C. § 1307)

Key Compliance Requirements

Who Must Comply

• U.S. importers of record for any goods with potential Xinjiang-region inputs
• Companies sourcing raw materials processed or refined in China
• Manufacturers importing components containing cotton, polysilicon, metals, or chemicals
• Non-U.S. exporters selling into the U.S. market through U.S. importers
• Companies assembling products in third countries using China-sourced inputs
• Distributors and retailers importing finished goods with multi-tier supply chains

Core Obligations

1. Supply Chain Due Diligence: Map supply chain to raw material origin; identify Xinjiang and Entity List exposure
2. Supply Chain Tracing: Maintain documentary evidence of material origin through every production tier
3. Detention Response: Provide "clear and convincing evidence" to CBP to rebut presumption and release goods
4. Entity List Screening: Screen all suppliers and sub-suppliers against the current UFLPA Entity List
5. Importer Compliance Program: Implement documented compliance program with supply chain management measures

UFLPA-Specific Pain Points

• The Sub-Tier Visibility Gap: CBP requires origin evidence through every production tier—not just Tier 1 suppliers.
• The Detention Clock: Importers have limited time to compile evidence when a shipment is detained.
• The Raw Material Pivot: Expanded high-priority sectors lead to increased risk of detention.
• The Evidence Standard Trap: Required evidentiary standards are challenging to meet.

UFLPA Workflow

GET EVIDENCE IN: Collect Origin Declarations and Tracing Documentation from Every Supplier Tier.

MAKE SENSE OF IT: Know Which Products Have Xinjiang or Entity List Exposure.

PROVE COMPLIANCE OUT: Respond to CBP Detentions in Days, Not Weeks.

Key Statistics

• 95%: Supplier response rate with CORA-powered campaigns
• 99.2%: Origin data extraction accuracy from supplier documents

Frequently Asked Questions

• What goods are covered by UFLPA? UFLPA applies to all goods mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of China, or by any entity on the UFLPA Entity List.

• What happens when CBP detains a shipment under UFLPA? The importer must provide "clear and convincing evidence" that the goods were not produced with forced labor.

• Does Certivo support UFLPA alongside other forced labor regulations? Yes, Certivo validates supplier origin evidence against multiple frameworks simultaneously.