UFLPA Entity List Hits 187 Entities: Largest-Ever Expansion Includes Companies Located OUTSIDE Xinjiang

On July 31, the Department of Homeland Security added 43 Chinese companies to the UFLPA Entity List, marking the largest expansion since the law came into effect. The list has now increased to 187 entities, a rise of 30 percent in a single notice. Beginning on August 3, CBP will assume that goods linked to these companies have been produced using forced labor and will therefore detain them at the port. The new entries cover aluminum, cotton and clothing, copper, pharmaceuticals, food, gold, titanium, and battery materials, and some of the added companies are not in any way connected with Xinjiang. More than 24,300 shipments worth nearly one billion dollars have already been blocked under this power. 

The effective date is Monday, August 3, because on that day CBP begins applying the presumption to these companies, and the updated list is also published in the Federal Register.

All of the tariffs that we have looked at this month have resulted in higher landed costs for someone. Unlike the tariff measures we have covered this month, which raise your landed cost, a UFLPA detention stops your goods entirely. Your inventory sits at the port while you assemble the documentation needed to release it — and the customer's order waits with it. Basically, if any of your goods come into contact with any of the 43 new names at any stage in your supply chain, CBP will assume that forced labor has been used and will hold the goods at the port.

This time there's a complication: a supplier can prepare this list using any province in China. 

What a Listing Does

The law is blunt.

The Uyghur Forced Labor Prevention Act states that any goods which have been mined, produced or manufactured entirely or in part by a company on the list are deemed to have been made with forced labor and are therefore forbidden from entering the United States; the Customs and Border Protection agency will detain such goods at the port, and it then becomes your responsibility to provide clear and convincing evidence that forced labor has not been used in the process, which in reality requires documentation tracing back to the raw materials.

Look at the figures. A tariff increases your landed cost, and you can calculate it and charge accordingly. If your goods are detained, then your inventory is tied up as you put together the necessary documentation, and the customer's order stays at the port the entire time.

What's in the August 3 Expansion

• The number of companies has increased by 43 this time, which is the greatest rise since the list started and has raised the total to 187 companies.
• Starting on Monday, August 3, 2026, the presumption will apply at entry when the revised list is published as an appendix to a Federal Register notice.
• The sectors that have been given high priority include aluminum, apparel and cotton, copper, and tomatoes as well as their downstream products; the complete list also covers pharmaceuticals, the food and agriculture sectors, gold, titanium, and battery materials such as lithium carbonate.
• The two companies in question are now known as Xinjiang Goens Energy Technology (for polysilicon) and Kuitun Yadasi Textile (for yarn); accordingly, Xinjiang GCL New Energy Material Technology and Xinjiang Tianmian Foundation Textile have been renamed. The renamed entities remain included on the list, so when screening you should use the current names, the former names, and the known aliases.

The specific information relating to each entity is now available on the DHS website, and the names will appear in the Federal Register on Monday.

How a Company Outside Xinjiang Makes the List

The 43 additions were divided into two groups, and the law underlying each of them is important.

The list included four companies that had been working with the Xinjiang government to recruit, transport or accept workers who were moved out of the area, one of them being Zhengzhou Synear Food, a firm which produces frozen dumplings and wontons in Henan Province, and which appeared on the list for accepting transferred Uyghur workers.

The remaining 41 companies were put on the list because they had been obtaining materials from Xinjiang via state-sponsored labour schemes, such as the "poverty alleviation" and "pairing-assistance" programs; this group comprises companies with their headquarters in Gansu, Shandong, Fujian, Anhui, Shaanxi, Jiangsu, Hunan, and Guangxi.

Your supplier file might already contain some of those names. Fujian Septwolves obtains Xinjiang cotton for use in its men's clothing. Chacha Food sources red dates, seeds and nuts from the region for its snack products. Baiyin Nonferrous operates a mine in Xinjiang and extracts copper and molybdenum. Shandong Gold runs the largest single gold mine in Xinjiang, and two subsidiaries of Tianshan Aluminum based in Jiangsu appeared on the list as suppliers of their aluminum.

In 2022, the usual solution was to remove all the addresses from Xinjiang from the supplier list and then consider the problem solved. But these entries still manage to go unnoticed by that check. A company can end up being listed as being from any province in China if its raw materials, workers, or inputs can be traced back to Xinjiang.

The Enforcement Numbers Keep Climbing

Since the UFLPA came into effect, the CBP has turned down more than 24,300 shipments valued at $1 billion. Washington is also increasing its efforts in this area. The DHS-DOJ Trade Fraud Task Force has recently reached over $1 billion in penalties, recoveries, and charged losses, with forced labor designated as a priority.

DHS Assistant Secretary for Trade and Economic Security Aris Kourkoumelis warned that "those who attempt to circumvent today's action and knowingly import goods produced with forced labor will be prosecuted to the fullest extent of the law."

Set this next to the forced-labor tariffs that took effect on July 24, and the pattern is hard to miss: tariffs on economies that tolerate forced labor, entry bans on companies tied to it.

What Importers Should Do Before Monday's Enforcement Begins

1. Check your supplier list today against the 43 new names, including those at tier 2 and tier 3 levels. The "wholly or in part" clause applies to raw materials.
2. Look at the current situation aboard the ship. Since the presumption holds at the date of entry, cargo that was covered and had sailed weeks earlier will still be detained if it arrives after Monday.
3. Make sure your screening tools are updated to include current names, previous names, and known aliases, starting with Goens Energy and Kuitun Yadasi, since systems that rely on exact name matches will fail to identify a company that has simply changed its official name.
4. Ask your suppliers of aluminum, cotton, food, and pharmaceutical inputs for copies of their sourcing certifications and obtain their origin story in writing.
5. Audit the contracts with Chinese manufacturers in each province; in this round nine provinces in addition to Xinjiang were included.
6. Set up your traceability file at once since it takes weeks to gather clear and convincing evidence when you start from scratch.
7. If your supply chain includes or may include a newly listed company, then get in experienced trade advice.

A Longer List, the Same Homework

The requirement remains the same as it has been since 2022: you must know your suppliers beyond the first level and have the documentation ready before CBP requests it. This expansion has significantly increased the cost of noncompliance.

Mallory Alexander's trade management and compliance team screens supplier lists against all 187 entities — including current names, former names, and aliases — and prepares the traceability files needed to release detained cargo. Under the UFLPA's rebuttable presumption, importers must provide clear and convincing evidence that detained goods were not produced with forced labor. Our traceability files are built to meet that evidentiary standard. Our licensed customs brokers manage detained entries directly with CBP, coordinating documentation submissions and communicating on your behalf throughout the review process. myMALLORY stores shipment status and documents in one place, so you can focus on resolution.

The least costly way to handle this problem is to catch it before the shipment arrives. Contact our M-Pact team to screen your suppliers against the updated list, tier by tier, with a documentation plan built around how you actually ship. 

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