The UFLPA Entity List is the official list of companies whose goods are subject to the UFLPA rebuttable presumption that they were produced with forced labor. The list is published and updated by the Forced Labor Enforcement Task Force (FLETF), chaired by the Department of Homeland Security, under Section 2(d)(2)(B) of the UFLPA.
The list has four categories:
- Entities in the Xinjiang Uyghur Autonomous Region that mine, produce, or manufacture goods using forced labor
- Entities working with the Chinese government to recruit, transport, transfer, harbor, or receive forced labor of Uyghurs, Kazakhs, Kyrgyz, Tibetans, or other persecuted groups out of the XUAR
- Entities that export products made by entities described in (1) or (2) from China into the United States
- Facilities and entities sourcing material from XUAR or from the persons described above for the purpose of "poverty alleviation" or "pairing assistance" labor schemes
Effect of listing:
- Goods produced by or with the involvement of a listed entity are presumed to be made with forced labor
- The presumption applies regardless of where the final assembly occurs — if any input came from a listed entity, the entire good is presumed tainted
- CBP detains shipments based on supply-chain links to listed entities
Practical compliance impact:
- Importers must screen all suppliers, sub-suppliers, and raw material sources against the current Entity List
- The list grows over time and is not static — screening must be ongoing
- Even minor inputs (e.g., cotton lint sourced from XUAR for cotton-blend textiles) can trigger detention of finished goods imported from third countries
- DHS publishes the full list and updates at www.dhs.gov/uflpa-entity-list
Effective reasonable care requires documented supply-chain mapping that can demonstrate, on demand, the absence of UFLPA Entity List links in every input.