The impact of the Uyghur Forced Labor Prevention Act (UFLPA)
Human rights

The impact of the Uyghur Forced Labor Prevention Act (UFLPA)

The Uyghur Forced Labor Prevention Act (UFLPA) took effect in June 2022. Which measures have been implemented, what does this US law mean for you, and what's new?

What is the UFLPA?

The Uyghur Forced Labor Prevention Act (UFLPA) came into effect on June 21, 2022.

The United States passed the UFLPA with the aim of preventing companies from profiting from products manufactured using forced labor from the Xinjiang-Uyghur Autonomous Region in China. The law pursues this objective by prohibiting US imports of goods with ties to forced Uyghur labor.

The US agency responsible for the UFLPA is the Department of Homeland Security, while Customs and Border Protection (CBP) is tasked with carrying out US import controls and implementing additional measures.

As part of the UFLPA rollout, US authorities also introduced a new restricted party list: The UFLPA Entity List contains the names of companies in Xinjiang-Uyghur that mine, produce, or manufacture goods, wares, articles, or merchandise wholly or in part using forced labor. Changes are published in the US Federal Register. The initial entries in the UFLPA Entity List came into force on June 21, 2022.

Other official information on the UFLPA and a good overview of the US Department of Homeland Security can be found here.

Uyghur Forced Labor Prevention Act Statistics

In March 2023, the CBP introduced a UFLPA enforcement statistics dashboard to let companies track metrics such as the number of denied shipments, affected industries, and the countries of origin impacted by the UFLPA.

In 2026, the CBP has updated its dashboard to make it clearer and more transparent for stakeholders. Key improvements include new data options, the ability to view shipment counts or values, more detailed commodity classifications (HTS-4), and visibility of all countries of origin. 

The definition of a "shipment" for the purpose of this dashboard has also changed: Previously, one shipment was defined as an aggregate of the totality of goods subjected to UFLPA enforcement actions on one CBP cargo release entry. This could include multiple line items or import transactions. 

Under this year's change, a shipment is now defined as an individual import transaction, typically representing a specific product or item being imported, within a shipment entry or customs declaration. A shipment is equivalent to an individual transaction subjected to UFLPA enforcement action.

This means, for example, if three products in one CBP cargo release entry are subject to enforcement, they are now counted as three shipments instead of one. The total value of shipments stopped remains unchanged, but the number of enforcement actions appears higher due to more detailed tracking. 

A stopped shipment refers to one that is flagged by CBP's system for possible UFLPA violations and is subject to further review, such as checking documents or inspecting cargo. Not all stopped shipments are physically detained or examined.

What is the impact of the UFLPA on US imports?

To date, 69,415 shipments with a total of US$3.94 billion have been affected since the UFLPA has taken effect. 

  • 25,292 (37%) of these have been denied
  • 41,859 (60%) have been released
  • 2,264 (3%) are currently pending decision 

The three industries most heavily impacted (by value) are:

  1. Electronics (US$3.28 billion)
  2. Base metals (US$96.6 million)
  3. Industrial and manufacturing materials (US$90.74 million)

Next up in terms of impact by value are machinery, automotive & aerospace, pharmaceuticals, health and chemicals, consumer products and mass merchandising, agriculture and prepared products, and petroleum, natural gas, and minerals. 

The storage costs of all detained shipments are billed to the US importer, and cleared shipments are not released until payment has been rendered.

Numbers above reflect the date of this article.

To see latest figures, please refer to the interactive CBP dashboard.

Automated UFLPA Entity List check

The UFLPA Entity List is included in the library of lists checked by AEB’s Compliance Screening software. This gives you an easy, convenient option to run a fully automated check in the background of your business processes.

Who is affected, and what does it mean for supply chains?

Countries of origin of affected shipments include nations from all over the globe including from Europe, Africa, the Americas, Australia, and of course, Asia. 

By shipment value, countries of origin most affected are: 

  • Malaysia (US$1.63 billion)
  • Vietnam (US$1.03 billion)
  • Thailand (US$548.11 million)
  • China (US$471.53 million)
  • India (US$85.32 million)
  • Mexico (US$55.6 million)

Although the UFLPA targets China’s Xinjiang-Uyghur region, statistics published by CBP make it clear that other countries often act as intermediaries, using raw materials from Xinjiang-Uyghur.

For this reason, it is recommended that companies – US-based importers, manufacturers in Asia, and those with supply chain partners in the affected countries – expand their due diligence processes beyond just Chinese suppliers and business partners. As with all business partner checks, it is important here as well to keep good records of all due diligence operations and have documentation ready for compliance audits.

For every player in affected supply chains, these latest developments with the UFLPA are a renewed call to carefully examine supply chains and ensure there is no involvement with human rights abuses.

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