US importers and brands
Carry the burden of proof when CBP detains a shipment. They need the traceability file ready before goods ship.
US · Customs · Public Law 117-78
UFLPA: traceability down to the raw material.
The Uyghur Forced Labor Prevention Act presumes that goods made wholly or partly in Xinjiang, or by entities on the UFLPA Entity List, are made with forced labour, and US Customs and Border Protection has enforced that presumption since 21 June 2022. US importers keep goods moving with traceability to raw-material origin: documents showing where every input came from, down to the cotton, polysilicon, aluminium or PVC.
- 21 Jun 2022
- presumption enforced by CBP
- 5
- priority sectors added in Aug 2025
- 43
- entities added on 31 Jul 2026
Status · checked 28 Sep 2026 Enforced since 21 Jun 2022
- UFLPA enacted
- Rebuttable presumption enforced
- Strategy update: five new priority sectors
- 43 companies added to the Entity List
- 28 Sep 2026
The short answer
What you need to know.
Checked against official sources on 28 September 2026.
- 01
The UFLPA (Public Law 117-78) was enacted on 23 December 2021. Since 21 June 2022, CBP applies a rebuttable presumption that goods made wholly or in part in Xinjiang, or by listed entities, are made with forced labour and may not enter the US.
- 02
The presumption reaches every input. A product assembled in India, Vietnam or China is detained if its cotton, yarn, polysilicon, aluminium or PVC traces back to Xinjiang or a listed entity.
- 03
To obtain an exception, the importer must follow the UFLPA guidance, answer CBP’s requests completely and substantively, and show by clear and convincing evidence that no forced labour was involved (Sec. 3(b)).
- 04
High-priority sectors include apparel, cotton, polysilicon, tomatoes, aluminium, PVC and seafood; the August 2025 update added caustic soda, jujubes, copper, lithium and steel.
- 05
The Entity List keeps growing: on 31 July 2026 DHS added 43 companies. Re-screen suppliers and their input suppliers after each update.
Who it applies to
If it enters the US, its inputs are in scope.
Direct suppliers
Must show that no inputs come from Xinjiang or listed entities, including through their own suppliers.
India, Vietnam and beyond
In scope through their inputs: Chinese yarn, fabric, aluminium extrusions, PVC compounds or polysilicon.
Mills, spinners, smelters
Hold the records that close the chain: purchase and production records for raw materials.
Key dates
Every date, with its source.
UFLPA is already fully in force. These are the milestones that changed what importers need to check.
-
UFLPA enacted
Public Law 117-78 signed into law.
-
Rebuttable presumption enforced
CBP begins applying the presumption to goods linked to Xinjiang or listed entities.
-
Strategy update: five new priority sectors
Caustic soda, jujubes (red dates), copper, lithium and steel added to the high-priority sectors.
-
43 companies added to the Entity List
The largest single expansion so far, according to commentators, with many entities in aluminium, apparel, cotton and tomatoes.
- Today · 28 September 2026
Example trace
One T-shirt, five tiers of evidence.
Example: a cotton T-shirt sewn in Vietnam for a US brand. The presumption looks through every tier, so the file does too.
- Tier 0US importerEntry documents, commercial invoice
- Tier 1Garment factory, VietnamProduction records, fabric receipts
- Tier 2Fabric millYarn purchase orders and lot records
- Tier 3Spinning millCotton bale purchases, invoices, payments
- Tier 4Cotton originOrigin records for each bale lot
Example, shown to illustrate the method. Real chains often branch: trims, thread and packaging have their own tiers.
What you need from suppliers
A traceability file that answers CBP.
Documents that connect each shipment to its raw material, and that reconcile with each other on quantities and dates.
- Supply chain map for each productEvery tier from the finished-goods factory to the raw material, with names and addresses.
- Purchase orders and invoices at each tierLinking the quantities bought to the quantities used in your order.
- Production recordsBatch or lot records showing which inputs went into which production run.
- Transport documents for inputsBills of lading, packing lists and delivery notes that confirm where inputs came from.
- Proof of paymentPayments that match the invoices at each tier of the chain.
- Raw-material origin evidenceOrigin records for cotton bales, mill certificates for steel and aluminium, and similar evidence per input.
How SourceSquid helps
From your product list to an audit-ready file.
Our teams in Bengaluru and Ningbo collect the evidence at the factory, in the supplier’s own language, while production runs.
- 01
Risk screen
Your products checked against the high-priority sectors and the inputs most likely to trace to Xinjiang.
You receiveUFLPA risk map - 02
Entity screening
Suppliers and their input suppliers screened against the UFLPA Entity List, and re-screened after every update.
You receiveScreening record - 03
Tier-n mapping
Our teams in Ningbo and Bengaluru trace each chain to spinner, smelter or compounder, on site where needed.
You receiveTraceability map - 04
Document collection
Purchase, production, transport and payment records gathered at each tier and checked so quantities reconcile.
You receiveReconciled document set - 05
Alternative inputs
Where a chain cannot be proven, we source inputs with clear origin, often in India.
You receiveQualified alternative supplier - 06
Detention-ready file
One organised file per product, ready for your customs broker if CBP asks.
You receiveAudit-ready traceability file
Sources
Official texts behind this page
Checked on 28 September 2026. This page explains the rules in plain English; for a view on your own products, ask our team or your legal adviser.
- US Customs and Border Protection: Uyghur Forced Labor Prevention ActRebuttable presumption; exceptions; applicability reviews
- US Department of Homeland Security: UFLPA Strategy
- US Department of Homeland Security: UFLPA Entity List
- US Department of Labor: 2025 UFLPA Strategy update (19 Aug 2025)Five new high-priority sectors
- Thompson Hine: UFLPA annual strategy update (commentary)Sectors designated 2022–2025
- Covington: DHS expands UFLPA Entity List (commentary, Aug 2026)43 entities added on 31 July 2026
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UFLPA questions
Straight answers.
Dates checked against official sources. We update this page when the rules move.
anirudh@sourcesquid.coWhat is the UFLPA rebuttable presumption?
Since 21 June 2022, US Customs and Border Protection presumes that goods mined, produced or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or by an entity on the UFLPA Entity List, are made with forced labour and are barred from import into the United States. The presumption applies to every input, not just the finished product.
How can an importer overcome the UFLPA presumption?
Under Section 3(b) of the Act, CBP may grant an exception only if the importer has fully complied with the UFLPA guidance, has completely and substantively responded to all CBP requests for information, and shows by clear and convincing evidence that the goods were not made wholly or in part with forced labour. Separately, an importer can show the goods have no connection to Xinjiang or listed entities through an applicability review.
Which sectors are high priority for UFLPA enforcement?
Sectors named in the UFLPA Strategy before 2025 are apparel; cotton and cotton products; silica-based products including polysilicon; tomatoes and downstream products; aluminium; PVC; and seafood. The 19 August 2025 update added caustic soda, jujubes (red dates), copper, lithium and steel.
Does UFLPA affect products made in India or Vietnam?
Yes, if any input traces back to Xinjiang or to a listed entity. A garment sewn in Vietnam or India from yarn or cotton sourced from Xinjiang is covered by the presumption. That is why traceability has to reach the raw material, not just the final factory.
How often does the UFLPA Entity List change?
It is updated from time to time by the Forced Labor Enforcement Task Force. On 31 July 2026, DHS added 43 companies, described by commentators as the largest single expansion so far, with many in aluminium, apparel, cotton and tomatoes. Screen suppliers and their input suppliers after every update.
Start here
Every input traced. Every shipment ready.
Send us the products you import into the US. We return a UFLPA risk map and the traceability plan for each supply chain.