Understanding the Uyghur Forced Labor Prevention Act (UFLPA)

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

• 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.

• 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.

• Map your supply chain
• Identify and assess forced labour risks
• Manage due diligence across all tiers