Yesterday, the U.S. Department of Homeland Security (DHS) added two Chinese entities—Baowu Group Xinjiang Bayi Iron and Steel Co., Ltd. (Xinjiang Bayi) and Changzhou Guanghui Food Ingredients Co., Ltd.(Changzhou Guanghui)—to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. This marks the first time that manufacturers of steel and aspartame have been targeted under the law.
Although only two new entities were officially named, the additions also include two subsidiaries of the listed companies as aliases, bringing the actual number of newly listed entities to four.
Steel and Aspartame Companies in the Spotlight
Xinjiang Bayi is the first steel company to be listed for alleged involvement in forced labor practices. Headquartered in Xinjiang, the company is owned by the Baowu Group, a Chinese state-owned company and the world’s largest steel producer.
Changzhou Guanghui, a producer of aspartame—a widely used artificial sweetener—also stands out as a significant addition. Unlike Baowu, Changzhou Guanghui is not based in Xinjiang. However, the U.S. government stated that the company has sourced raw materials from the region, linking it to forced labor practices. This inclusion is based on "specific and articulable information," emphasizing that forced labor violations are not limited to companies physically located in Xinjiang but also extend to those benefiting from its resources.
On its website, Changzhou Guanghui reports that a subsidiary in the Xinjiang region—not listed or included as an alias—serves as its "production base" for phenylalanine, the key raw material in aspartame manufacturing.
Trade data reviewed by Kharon suggests that Changzhou Guanghui has exported aspartame powder to customers in India, Vietnam, and Mexico, raising concerns about the potential reach of products tied to forced labor in global supply chains.
Subsidiaries Increase Entity Count
The announcement also highlights several aliases for the two newly listed companies. However, a review of corporate records and company websites by Kharon has revealed that two companies—Xinjiang Bayi Iron and Steel Co., Ltd. and Changzhou Guanghui Food Technology Co., Ltd.—added as aliases for Xinjiang Bayi and Changzhou Guanghui respectively, are separately registered subsidiaries.
This means that, while two primary entities were named, the total number of newly listed companies effectively rises to four.
The inclusion of subsidiaries of the newly added entities as aliases has significant implications for trade and compliance. Under the UFLPA, the U.S. Customs and Border Protection (CBP) will theoretically apply a rebuttable presumption that goods produced by these subsidiaries—like those of the listed companies—are prohibited from entering the United States.
Technical Correction: Name Change of Listed Entity
The announcement also included a "technical correction" regarding a previously listed entity, Hefei Meiling Co., Ltd., which has changed its name to Changhong Meiling Co., Ltd. This name change reflects updates in the company's registration but does not affect its status on the UFLPA Entity List.
Although only two new entities were officially named, the additions also include two subsidiaries of the listed companies as aliases, bringing the actual number of newly listed entities to four.
Steel and Aspartame Companies in the Spotlight
Xinjiang Bayi is the first steel company to be listed for alleged involvement in forced labor practices. Headquartered in Xinjiang, the company is owned by the Baowu Group, a Chinese state-owned company and the world’s largest steel producer.
Changzhou Guanghui, a producer of aspartame—a widely used artificial sweetener—also stands out as a significant addition. Unlike Baowu, Changzhou Guanghui is not based in Xinjiang. However, the U.S. government stated that the company has sourced raw materials from the region, linking it to forced labor practices. This inclusion is based on "specific and articulable information," emphasizing that forced labor violations are not limited to companies physically located in Xinjiang but also extend to those benefiting from its resources.
On its website, Changzhou Guanghui reports that a subsidiary in the Xinjiang region—not listed or included as an alias—serves as its "production base" for phenylalanine, the key raw material in aspartame manufacturing.
Trade data reviewed by Kharon suggests that Changzhou Guanghui has exported aspartame powder to customers in India, Vietnam, and Mexico, raising concerns about the potential reach of products tied to forced labor in global supply chains.
Subsidiaries Increase Entity Count
The announcement also highlights several aliases for the two newly listed companies. However, a review of corporate records and company websites by Kharon has revealed that two companies—Xinjiang Bayi Iron and Steel Co., Ltd. and Changzhou Guanghui Food Technology Co., Ltd.—added as aliases for Xinjiang Bayi and Changzhou Guanghui respectively, are separately registered subsidiaries.
This means that, while two primary entities were named, the total number of newly listed companies effectively rises to four.
The inclusion of subsidiaries of the newly added entities as aliases has significant implications for trade and compliance. Under the UFLPA, the U.S. Customs and Border Protection (CBP) will theoretically apply a rebuttable presumption that goods produced by these subsidiaries—like those of the listed companies—are prohibited from entering the United States.
Technical Correction: Name Change of Listed Entity
The announcement also included a "technical correction" regarding a previously listed entity, Hefei Meiling Co., Ltd., which has changed its name to Changhong Meiling Co., Ltd. This name change reflects updates in the company's registration but does not affect its status on the UFLPA Entity List.
In February, Kharon reported that Changhong Meiling Co. Ltd.—one of China’s largest manufacturers and distributors of home refrigerators and freezers—continued to ship its products to U.S. consumers after it was added to the UFLPA Entity List in October 2022.
Implications for Global Supply Chains
The latest actions by the DHS highlight the U.S. government’s ongoing commitment to combating forced labor in global supply chains, particularly those linked to Xinjiang.
“The UFLPA is catalyzing American businesses to fully examine and assess their supply chains and setting a new standard for our international partners as we work together to eradicate forced labor from the global economy,” said Secretary of Homeland Security Alejandro N. Mayorkas.
By targeting steel and aspartame companies for the first time, the U.S. government signals that no sector is beyond scrutiny.
“No sector is off-limits. We will continue to identify entities across industries and hold accountable those who seek to profit from exploitation and abuse,” said DHS Under Secretary for Policy Robert Silvers.
The inclusion of Changzhou Guanghui demonstrates that companies sourcing materials from Xinjiang, even if based outside the region, are subject to U.S. enforcement actions.
As a result, the CBP will now treat goods produced by these entities as presumptively made with forced labor, barring their importation into the U.S. unless clear and convincing evidence to the contrary is provided.
The latest actions by the DHS highlight the U.S. government’s ongoing commitment to combating forced labor in global supply chains, particularly those linked to Xinjiang.
“The UFLPA is catalyzing American businesses to fully examine and assess their supply chains and setting a new standard for our international partners as we work together to eradicate forced labor from the global economy,” said Secretary of Homeland Security Alejandro N. Mayorkas.
By targeting steel and aspartame companies for the first time, the U.S. government signals that no sector is beyond scrutiny.
“No sector is off-limits. We will continue to identify entities across industries and hold accountable those who seek to profit from exploitation and abuse,” said DHS Under Secretary for Policy Robert Silvers.
The inclusion of Changzhou Guanghui demonstrates that companies sourcing materials from Xinjiang, even if based outside the region, are subject to U.S. enforcement actions.
As a result, the CBP will now treat goods produced by these entities as presumptively made with forced labor, barring their importation into the U.S. unless clear and convincing evidence to the contrary is provided.
