The Forced Labor Enforcement Task Force is adding 26 companies to the Uyghur Forced Labor Prevention Act Entity List, the largest-ever one-time expansion of that list. The newly-added companies are China-based cotton traders or warehouse facilities, most of which operate outside China’s Xinjiang Uyghur Autonomous Region, that the U.S. has reasonable cause to believe source cotton from the XUAR. Effective May 17, goods produced by these entities will be prohibited from entering the U.S.

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. With the most recent additions there are now 65 companies on this list.

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

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