The Department of Homeland Security published 2025 Updates to the Uyghur Forced Labor Prevention Act Strategy. The updates add caustic soda, copper, jujubes (red dates), lithium, and steel as high-priority sectors for enforcement and offers other information on identified entities as well:
“Since the 2024 Updates … through the publication date of this report, the Forced Labor Enforcement Task Force has added 78 entities, removed one entity, and made three technical corrections [detailed in Appendix A with the updated products list updates in Appendix B] …
The Forced Labor Enforcement Task Force has prioritized expansion of the Uyghur Forced Labor Prevention Act Entity List with a focus on entities that egregiously and openly engage in behavior covered by the Uyghur Forced Labor Prevention Act [and] continues to pursue new technology and new methods to identify companies under all relevant sub-lists of the Uyghur Forced Labor Prevention Act Entity List.”
The update reminds importers involved in all high priority sectors that they are “on notice to more closely review each tier in their supply chains to enhance transparency and focus due diligence efforts on the supply chain nodes involving these sectors and enable enhanced streamlining and strengthening of compliance protocols to eliminate goods made with forced labor.”
I don’t expect UFLPA enforcement and importation bans to ease anytime soon – companies must continue to prioritize supply chain due diligence and obtaining adequate evidence to support the UFLPA rebuttable presumption.
Members can read more about UFLPA here.
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