US UFLPA · Uyghur Forced Labor Prevention Act
A rebuttable presumption applies to goods mined, produced or manufactured wholly or in part in Xinjiang, or by UFLPA Entity List entities, unless the statutory exception and evidence requirements are met.
Industries: PV / Battery / Textile / Aluminium / Auto
- 2021.12.23UFLPA signed into law
- 2022.06.21★Fully in force (enforcement begins)
- 2024.07FLETF publishes its 2024 strategy update; priority sectors and the entity list continue to evolve
- 持续滚动CBP / FLETF continually update the entity list & high-risk sectors
AMT: Traceability · Carbon-Link · Assurance · DPP
Overview
- Full name
- Uyghur Forced Labor Prevention Act (UFLPA) · U.S. Public Law 117-78
- Authority
- U.S. Customs and Border Protection (CBP) + Forced Labor Enforcement Task Force (FLETF)
- Effective
- In full force since 2022.06.21 (ongoing enforcement)
- Scope
- Goods linked to Xinjiang production / suspected forced labour (entity list + high-risk sectors)
- Mechanism
- Rebuttable presumption — Xinjiang-linked goods presumptively barred unless rebutted with “clear and convincing evidence”
UFLPA has been enforced since 21 Jun 2022. Its core is not a fixed sector list but a rebuttable presumption for Xinjiang-linked production and UFLPA Entity List entities. An importer seeking an exception must fully respond to CBP requests and provide clear and convincing evidence that the goods were not made wholly or in part with forced labour. Cotton, tomatoes and polysilicon are statutory strategy priorities, while FLETF updates high-priority sectors and the entity list. The former claim that a new lithium, steel and copper tracing rule began in Aug 2025 was not supported by an official rule and has been removed. Battery, storage and metal products should be assessed case by case against actual upstream origin and the current entity list.
Timeline
From entry into force to key milestones — every compliance checkpoint.
- 2021.12.23UFLPA signed into law
- 2022.06.21Fully in force (enforcement begins)
- 2024.07FLETF publishes its 2024 strategy update; priority sectors and the entity list continue to evolve
- 持续滚动CBP / FLETF continually update the entity list & high-risk sectors
Who must comply
Self-check across industry, scale and export scope.
Cotton / tomatoes / polysilicon are statutory strategy priorities; other sectors depend on the latest FLETF strategy, entity list and actual supply chain.
Do you export to the U.S., and does your chain touch Xinjiang — even indirectly?
Regardless of size — any relevant goods entering the U.S. are subject to enforcement.
Key requirements
Meet these core requirements to comply and access the market.
Supply-chain due diligence: trace the full chain to raw materials and map the entire supply chain.
Rebuttal evidence: the “clear and convincing” standard, far above ordinary due diligence.
Entity-list screening: avoid direct or indirect dealings with listed entities.
Priority areas: cotton, tomatoes, polysilicon and high-priority sectors in the latest FLETF strategy require deeper, verifiable due-diligence evidence.
Enforcement outcomes: CBP may detain, exclude, or seize/forfeit goods; importers must respond within the applicable period or re-export.
AMT product mapping
Precisely matched from the 13-product matrix to cover this regulation end to end.
Full-chain traceability to raw materials + batch-level verifiable evidence.
View productCollaborative collection of upstream due-diligence data.
View productThird-party due-diligence and evidence verification.
View productSmart entity-list screening + supply-chain risk alerts.
View productResources & official docs
FAQ
What does “clear and convincing evidence” require?
A full supply-chain map, raw-material traceability, production records, and labour / procurement documentation — verifiable evidence that no stage involves Xinjiang forced labour.
We don’t source directly from Xinjiang — why could shipments still be detained?
UFLPA looks at the full chain. Materials from tier-2 or tier-3 suppliers linked to Xinjiang can trigger the presumption, so you must trace and document upstream tier by tier.
Why are polysilicon / PV among the highest-risk?
Global polysilicon capacity is highly concentrated and CBP treats it as a priority; PV modules to the U.S. are routinely asked for full traceability evidence from polysilicon to module.
Are battery / energy-storage products automatically a UFLPA high-risk sector?
Not automatically by product label. The key questions are whether any part was produced in Xinjiang, whether an UFLPA Entity List entity is involved, and how CBP assesses the supply-chain evidence. US-bound battery and storage exporters should still trace mineral, material and component origins and screen entities by tier.