The Department of Homeland Security announced June 11 that it is adding three China-based companies to the Uyghur Forced Labor Prevention Act Entity List because it has reasonable cause to believe that they work with the government of China’s Xinjiang Uyghur Autonomous Region to recruit, transport, transfer, harbor, or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the XUAR. Effective June 21, goods produced by these entities will be prohibited from entering the U.S.

According to DHS, the newly-added companies (1) process, sell, and export frozen seafood products, vegetables, quick-frozen convenience food, and other aquatic foods, (2) produce and manufacture shoes and shoe material products, and (3) produce electrolytic aluminum, graphite carbon, and pre-baked anodes. DHS states that these additions signal an increase in its focus on the seafood, aluminum, and footwear sectors, which “play an important role” in the XUAR economy. Other sectors represented on the Entity List, which now comprises 68 companies, include agriculture, apparel, batteries, chemicals, electronics, food additives, household appliances, nonferrous metals, polysilicon, and plastics.

The UFLPA Entity List is a consolidated register of the four lists required to be developed and maintained under that law: (1) entities in the XUAR that mine, produce, or manufacture wholly or in part any goods, wares, articles, and merchandise with forced labor, (2) entities working with the XUAR government to recruit, transport, transfer, harbor, or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the XUAR, (3) entities that exported products made by any of the above entities from China into the U.S., and (4) facilities and entities, including the Xinjiang Production and Construction Corps, that source material from the XUAR or from persons working with the XUAR government or the XPCC for purposes of the “poverty alleviation” program or the “pairing-assistance” program or any other government-labor scheme that uses forced labor.

The UFLPA establishes a rebuttable presumption that goods made wholly or in part in the XUAR are made with forced labor and are therefore excluded from entry into the U.S. CBP applies this presumption to goods mined, produced, or manufactured by entities on the UFLPA Entity List, which are thus prohibited from importation into the U.S. under 19 USC 1307.

Sandler, Travis & Rosenberg has a robust program to assist companies on forced labor issues. ST&R also maintains a frequently updated web page offering a broad range of information on forced labor-related efforts in the U.S. and around the world. For more information, please contact ST&R at

Copyright © 2024 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.

ST&R: International Trade Law & Policy

Since 1977, we have set the standard for international trade lawyers and consultants, providing comprehensive and effective customs, import and export services to clients worldwide.

View Our Services 


Cookie Consent

We have updated our Privacy Policy relating to our use of cookies on our website and the sharing of information. By continuing to use our website or subscribe to our publications, you agree to the Privacy Policy and Terms & Conditions.