DHS Adds 29 Companies to Forced-Labor Blacklist

The U.S. Department of Homeland Security has announced that it will add 29 more companies to the expanding Uyghur Forced Labor Prevention Act (UFLPA) Entity List – the largest expansion of this import blacklist thus far. The additions go into effect Nov. 25, 2024. 

Companies on the UFLPA Entity List are entities in the Xinjiang region of China that have been found to mine, produce, or manufacture, wholly or in part, any goods, wares, articles and merchandise with forced labor. The list also includes entities found to have been working with the government of Xinjiang to recruit, transport, transfer, harbor or receive forced labor members of persecuted groups out of Xinjiang. 

This newest list targets mainly the agricultural sector, but also includes sectors in the mining and smelting of raw materials such as aluminum, lithium and other metals.  

Three key considerations for U.S. companies from this most recent news:

1. U.S. importers should consider conducting an internal review to ensure that parties on the UFLPA Entity List (now totaling almost 100 companies) are not anywhere in their supply chain, directly or indirectly
2. Even after verifying your supply chain is free of blacklisted entities, this recent news provides U.S. importers an opportunity to have further discussions with its international suppliers, especially those in China, about mitigating forced-labor risks. The UFLPA Entity List will only continue to grow.
3. Even if your international suppliers are outside of China, the UFLPA statistics page hosted by U.S. Customs and Border Protection (CBP) shows that the risk of detention of shipments and risk of potential penalties due to forced labor enforcement also greatly affect shipments from surrounding countries, most notably Malaysia, Vietnam and Thailand.