The Uyghur Forced Labor Prevention Act (UFLPA) is reshaping global trade and supply chain management. Enforced by the U.S. Customs and Border Protection (CBP) since June 2022, the law bans the import of goods made wholly or partly with forced labour in China’s Xinjiang Uyghur Autonomous Region or by any organisation listed on the official UFLPA Entity List.
For companies importing into the United States, compliance is a legal requirement.
What the UFLPA does
The UFLPA aims to:
Stop products made with forced labour from entering global markets
Protect vulnerable communities
Strengthen international human rights standards
The Act places the burden of proof on importers. All goods from Xinjiang are presumed to involve forced labour unless companies provide clear and convincing evidence that their supply chains are free from it.
This makes compliance difficult for businesses with large, multi-tier supply chains.
The cost of non-compliance
Failing to comply with the UFLPA can lead to serious and immediate consequences. Shipments may be:- Detained, seized, or denied entry at U.S. ports
- Subject to investigations that delay delivery
- Costly in terms of both finance and reputation
- Stopped 4,597 shipments valued at $1.71 billion for UFLPA review
- Denied 1,976 shipments
- Released 2,567 into U.S. commerce
Why UFLPA is compliance is so challenging
Traditional supplier questionnaires or basic audits rarely meet the “clear and convincing evidence” standard required by CBP. Companies must have deep visibility into every level of their supply chains, not just their direct suppliers.
1. Complex, High-Risk Industries
Sectors such as textiles, solar, electronics, and aluminium depend on materials like cotton, polysilicon, and metals that often originate in Xinjiang. These materials are frequently processed across several regions, making it difficult to prove their origin.
2. Globalised Supply Chains
Components often move through multiple countries before final assembly. Even when a company sources materials outside Xinjiang, indirect links to forced labour may still exist through intermediaries.
3. Expanding Global Regulations
The UFLPA is part of a broader global movement toward stricter due diligence requirements. In Europe, the Corporate Sustainability Due Diligence Directive (CSDDD) requires companies to identify and address human rights and environmental risks throughout their operations and supply chains. In Canada, the Fighting Against Forced and Child Labour in Supply Chains Act (2023) introduces similar expectations for transparency and accountability. Businesses that act early to strengthen their due diligence processes will be better prepared to meet these evolving international standards.
Technology as a compliance solution
Manual audits alone cannot handle the complexity of global supply chains. Technology can make compliance faster and more accurate.
The SUPPLIERASSURANCE platform, powered by NQC, provides a complete UFLPA compliance solution through four integrated modules. Together, they help organisations scan, map, monitor, and document their supply chains to meet regulatory standards.
Scans supplier networks using advanced analytics to uncover potential links to Xinjiang or restricted entities. By flagging risks rapidly, it enables businesses to take corrective action before issues escalate.
Traces goods back to their source and assigns automated risk ratings. This helps companies demonstrate that materials are not connected to high-risk regions and build evidence of compliance.
Provides continuous monitoring of suppliers and shipments, issuing timely alerts when potential risks are detected. This enables early intervention and reduces the likelihood of detentions and disruptions.
Consolidates affidavits, declarations, and supporting evidence in a centralised system, ensuring businesses can respond quickly and effectively to CBP enquiries with a defensible audit trail.
Complying with the UFLPA is more than a regulatory task. It provides long-term business value.
- Strengthen ESG performance: Show a clear commitment to ethical sourcing and human rights.
- Build resilience: Improve visibility across the supply chain and prepare for future regulations.
- Protect reputation: Transparency builds trust with regulators, investors, and customers.
Simplify UFLPA Compliance with NQC
The Uyghur Forced Labor Prevention Act has changed the standards for global trade. Businesses must now prove the integrity of their supply chains or face financial and reputational risks.
NQC’s SUPPLIERASSURANCE platform makes compliance straightforward.
Easily:
- Map your supply chain
- Identify and assess forced labour risks
- Manage due diligence across all tiers
Ensure compliance with the UFLPA.
Protect your business, your brand, and your supply chain with SUPPLIERASSURANCE, powered by NQC.
Speak to a UFLPA expert
SUPPLIERASSURANCE platform helps identify, assess, and address forced labour risks to support UFLPA compliance.
