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Import Procedures
Forced Labor Compliance for U.S. Importers (Including 2025 UFLPA Updates)
On: August 6, 2025 | By: 
Kari Crane |
5 min. read
While importers are scrambling to adapt to shifting tariffs, new geopolitical alliances and a volatile global shipping market, another force has been more quietly reshaping supply chains: the Uyghur Forced Labor Prevention Act (UFLPA). Since it took effect in June 2022, UFLPA has forcefully transformed import compliance, and in 2025, the pressure is only intensifying.
If you're focusing solely on duties and costs of your imports, you may be missing a bigger threat: shipment detentions, reputational damage and multi-million-dollar disruptions from forced labor enforcement. Here's what you need to know—and do—to stay compliant.
What Is UFLPA?
Signed into law in December 2021, the UFLPA reinforces a long-standing U.S. prohibition on importing goods made with forced labor. But this law added real teeth: It created a rebuttable presumption that all goods mined, produced or manufactured wholly or in part in China’s Xinjiang region, or by entities on the UFLPA Entity List, are made with forced labor and therefore banned from entering the U.S.
This means the burden of proof has shifted. Importers must present clear and convincing evidence that their goods are compliant before they're allowed entry.
To understand the UFLPA’s full scope and requirements, importers should refer to the official Department of Homeland Security (DHS) UFLPA website and the latest DHS Enforcement Strategy.
What Changed in 2025?
In the past year, enforcement has expanded:
Entity List Growth
As of the latest update in 2025, more than 150 entities are included on the list. These include major players in textiles, aluminum, chemicals, seafood and more. DHS now also counts subsidiaries individually to increase transparency. Importers must be vigilant—Shipping Solutions Restricted Party Screening Software makes it easy to check your suppliers against the growing UFLPA Entity List and all of the U.S. government's bad-guy lists, including subsidiaries and affiliates.
Broadened Industry Focus
Early enforcement targeted cotton and solar panels, but 2024 and 2025 have seen scrutiny expand to electronics, automotive, PVC, aluminum, seafood and critical minerals used in EV batteries. With the inclusion of new sectors, companies must strengthen their due diligence and supplier verification. The CBP UFLPA Statistics Dashboard provides updated enforcement data by industry.
New Reporting Tools
CBP launched a Forced Labor Allegations Portal allowing the public to report suspected violations—an initiative that increases transparency and accelerates investigations. Allegations may be reported anonymously. In this environment, it’s crucial that importers maintain thorough records and preemptively screen their partners. Our compliance software supports these efforts by creating an audit trail of your efforts.
More Enforcement Resources
DHS requested funding for 20 new UFLPA enforcement roles and committed to deeper collaboration with non-governmental organizations (NGOs), civil society and international partners. That means more eyes on your supply chain. Now is the time to analyze sourcing options. This Landed Cost Calculator can help you compare the total cost of sourcing from different regions, by calculating the various import duties, VAT and excise taxes, and other government fees you would need to pay. It will also flag products that might be subject to anti-dumping or countervailing duties. For example, easily compare the costs of a product sourced domestically against the cost of importing that same product from China or Mexico.
Forced Labor Enforcement by the Numbers
The result of the new enforcement? Between June 2022 and mid-2025, CBP reviewed more than 16,000 shipments, denied entry to 9,739, released 5,738 and placed the total shipment value under scrutiny at $3.67 billion.
Top industries impacted:
- Automotive & Aerospace: 5,490 shipments
- Electronics: 5,262 shipments
- Apparel & Textiles: 2,169 shipments
Beyond Xinjiang: Forced Labor Enforcement Is Global
While the UFLPA has brought significant attention to forced labor concerns in China’s Xinjiang region, importers must remember that U.S. law prohibits the importation of goods made with forced labor from any country. Section 307 of the Tariff Act of 1930 empowers CBP to detain products from any region of the world if forced labor is suspected.
CBP actively enforces Withhold Release Orders (WROs) on goods from other countries where forced labor has been documented. These include:
- Fishing and seafood from Southeast Asia
- Cocoa from West Africa
- Garments and textiles from South Asia
- Rubber gloves, palm oil and bricks from various regions
In each case, CBP can detain goods even if they are not covered under UFLPA.
To stay updated on non-UFLPA enforcement, importers should regularly check the CBP Withhold Release Orders and Findings page.
How Import Controls Software Can Help
With greater scrutiny, more industries impacted and a growing Entity List, UFLPA enforcement is a compliance issue importers cannot ignore.
But it’s not the only compliance issue importers need to understand. If you need help identifying whether your goods are subject to additional U.S. import requirements, Shipping Solutions Import Controls Software can help. By simply entering your product's HS number, along with the country of import, export and manufacture, the software shows whether your shipment is subject to controls like licenses, permits, quotas, sanctions or anti-dumping duties. This allows importers to catch red flags early and prepare the appropriate documentation to avoid delays or violations.
Learn more and sign up here for a free trial of all of our trade compliance software solutions.
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