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Keeping you in-the-know on environmental, social and governance developments

While we’re talking about UFLPA … On May 16, the U.S. Department of Homeland Security (DHS) added 26 textile companies to the list of entities whose goods will be restricted from entering the United States under the Uyghur Forced Labor Prevention Act (UFLPA). According to the DHS announcement:

“The 26 entities added to the UFLPA Entity List include cotton traders and warehouse facilities within China, the majority of which operate outside of the XUAR. Adding these entities to the UFLPA Entity List will make it easier for responsible companies to ensure that they are not purchasing cotton from entities who are sourcing cotton from the XUAR. By identifying these additional entities in the textile sector, U.S. importers have more information to conduct due diligence and examine their supply chains for risks of forced labor to ensure compliance with the UFLPA. The FLETF [Forced Labor Enforcement Task Force] determined that 21 of the entities source and sell cotton from the XUAR on the wholesale market. The FLETF also determined that five additional entities also source cotton from the XUAR.”

The action represents the largest ever one-time expansion to the UFLPA Entity List. There continues to be significant DHS activity and priority on UFLPA and DHS’ Textile Enforcement Plan, which prioritizes examination and review of entities in the textile sector for possible inclusion on the UFLPA Entity List. With so much emphasis on climate matters by US companies, it remains crucial to not forget about human right due diligence in your supply chains. And that isn’t just for foreign-produced goods as I will discuss in a future blog.

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Photo credit: Eric BVD –

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile