UFLPA: An Exercise in Adaptability

The Uyghur Forced Labor Prevention Act (UFLPA) is a US law prohibiting the import of goods manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China. The goal of the law is to prevent US companies from directly or indirectly contributing financially to forced labor found to be common among ethnic minorities in the Xinjiang region.  

The law is enforced by the US Customs and Border Protection (CBP), and has  rebuttable presumption provisions that make it difficult to challenge findings that a product or material came from either Xinjiang or the UFLPA Entity List, which consists of entities that have been lined to forced labor. Importing companies face a high barrier to proving their goods were not linked to forced labor once shipments have been detained.  

UFLPA Enforcement Statistics 

Since CBP began enforcing the UFLPA in June FY2022 there have been significant fluctuations trends that companies should be aware of.  

Despite the Xinjiang region being in China, the majority of shipment value seized was actually from Malasia, with Vietnam coming second. This is clear evidence that companies looking to maintain compliance can’t just assume that imports from places other than China are safe.  

Consistent attention to the changes in the UFLPA Entity List is key. Updates occur as new information comes in, so changes can happen monthly or even more frequently. 

With the next year of enforcement, we still see Vietnam and Malaysia take the top import investigation spots, but Chinese goods have now taken a distant fourth place after being supplanted by Thailand. We also see that electronics are the lion’s share of investigated shipments, and apparel, footwear and textiles have claimed second place.  

FYTD 2025 metrics up to May show a drastic change in enforcement. The majority of investigated shipments did come from China this year, and are primarily in the automotive and aerospace sector. Most notably, there is a huge percentage increase in denials, with about 79% of shipments turned away after investigation. There have already been over 1,500 more shipments investigated in FYTD 2025 than in all of FY 2024, showing that CBP is getting more serious about enforcement than in previous years.  

Conclusion 

The UFLPA is becoming a greater compliance challenge as time goes on, with shifting investigation priorities fluctuating fast. The need for compliance with these requirements is also becoming more important as tariff uncertainty may lead to greater losses for companies whose shipments are denied.  

Snaplinc’s supply chain experts are able to untangle complex UFLPA requirements and help you achieve clarity on the parts of your supplier network that pose the most risk. Reach out today for more critical information.