DHS Adds 43 Companies to the UFLPA Entity List, the Largest Expansion Yet
On July 31, 2026, the Department of Homeland Security, acting on behalf of the Forced Labor Enforcement Task Force (FLETF), announced the addition of 43 companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, along with technical updates to the official names of two entities already listed.
The New List
The revised list published as an appendix to a Federal Register notice on August 3, 2026, bringing the total to 187 entities, a roughly 30% increase, and the single largest expansion since the UFLPA took effect in 2022. The newly designated companies operate in DHS’s high-priority enforcement sectors, including aluminum, apparel, copper, cotton, and tomatoes and downstream products. Notably, a substantial share of the additions are headquartered outside the Xinjiang Uyghur Autonomous Region (XUAR), in provinces such as Shandong, Jiangsu, and Henan, which highlights that Entity List exposure is not a question of geography alone.
CBP’s UFLPA Authority
Under the UFLPA, U.S. Customs and Border Protection (CBP) applies the UFLPA’s rebuttable presumption under 19 U.S.C. § 1307 to goods mined, produced, or manufactured wholly or in part by any of the newly listed entities, and, critically, to downstream merchandise that incorporates their inputs. There is no de minimis threshold: a single component, raw material, or subassembly traceable to a listed company can support detention of an entire shipment.
To secure release, an importer must either show that the UFLPA does not apply to the merchandise or overcome the presumption with clear and convincing evidence, supported by complete supply chain traceability documentation back to the raw material. Both are demanding evidentiary standards, and CBP’s own statistics reflect it: since the statute’s implementation, CBP has denied entry to more than 24,300 shipments valued at nearly $1 billion. The enforcement environment surrounding these detentions has also sharpened, with DHS signaling that importers who knowingly circumvent UFLPA restrictions may face criminal exposure in addition to trade remedies.
What Importers Should Do
Importers sourcing in the affected sectors should not wait for a Notice of Detention to begin their diligence. Screen your direct suppliers and, just as importantly, map upstream tiers against the consolidated Entity List, because the risk in most UFLPA cases sits several levels above the vendor named on the commercial invoice. Refresh supplier certifications and contractual representations, confirm you can actually produce transaction-level records – purchase orders, production records, payment documentation, and transportation records – for each tier of the supply chain, and consider whether your CTPAT and internal compliance programs reflect the current list.
If you receive a detention notice, timelines move quickly, and the quality of the initial submission matters enormously. Diaz Trade Law regularly advises importers on UFLPA risk assessments, supply chain traceability, and responses to CBP detentions and exclusions. Contact us at [email protected] or (305) 456-3830 to discuss your exposure.
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