Effective June 12, the U.S. has banned imports from two entities and eight subsidiaries recently added to the Uyghur Forced Labor Prevention Act Entity List for working with the government of the 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.
- Xinjiang Zhongtai Chemical Co. Ltd.
- Ninestar Corporation and its eight Zhuhai-based subsidiaries, which include Zhuhai Ninestar Information Technology Co. Ltd., Zhuhai Pantum Electronics Co. Ltd., Zhuhai Apex Microelectronics Co. Ltd., Geehy Semiconductor Co. Ltd., Zhuhai Pu-Tech Industrial Co. Ltd., Zhuhai G&G Digital Technology Co. Ltd., Zhuhai Seine Printing Technology Co. Ltd., and Zhuhai Ninestar Management Co. Ltd.
The UFLPA Entity List is a consolidated register of the four lists required to be developed and maintained under that law.
- entities in the XUAR that mine, produce, or manufacture wholly or in part any goods, wares, articles, and merchandise with forced labor
- 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
- entities that exported products made by any of the above entities from China into the U.S.
- 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
U.S. Customs and Border Protection applies a rebuttable presumption that goods mined, produced, or manufactured by entities on the UFLPA Entity List are made with forced labor and therefore 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 supplychainvisibility@strtrade.com.
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