UFLPA Enforcement and Compliance: What Supply Chain Executives Need to Know

As U.S. Customs and Border Protection (CBP) intensifies enforcement under the Uyghur Forced Labor Prevention Act (UFLPA), supply chain leaders face growing risk. From detentions and denied shipments to reputational damage, UFLPA noncompliance carries real consequences.

Here, we break down what executives need to know now—covering UFLPA’s scope, evolving enforcement trends, and proven strategies to reduce supply chain exposure.

An Overview of the UFLPA (Uyghur Forced Labor Prevention Act)

The Uyghur Forced Labor Prevention Act (UFLPA) is a U.S. law that restricts the entry of goods into the U.S. market if they’re manufactured, whether wholly or partially, with forced labor from Xinjiang, China—or by entities associated with Uyghur forced labor.

Enacted in 2021 and implemented in 2022, the law aims to further eliminate the use of forced labor in global supply chains. It impacts both U.S.-based companies as well as international companies that do business with companies in the U.S.

How the UFLPA Is Enforced

CBP enforces the UFLPA at the border by detaining suspect shipments. To release goods, importers must present “clear and convincing evidence” that no forced labor was involved. If the evidence is insufficient, the shipment is denied entry.

Goods and Entities Subject to the UFLPA

Several product categories have been identified as high-risk under the UFLPA due to their strong ties to supply chains in the Xinjiang region, including cotton, tomatoes, and polysilicon (used in solar panels). More recently, scrutiny has expanded to include lithium-ion batteries, aluminum, seafood, polyvinyl chloride (PVC), and electronics.

The UFLPA targets:

• Goods mined, produced, or manufactured wholly or in part in the XUAR
• Products made by entities on the UFLPA Entity List
• Goods incorporating raw materials or components sourced through forced labor, including labor transfers or internment camps

UFLPA Requirements and Responsibilities

CBP holds importers accountable for verifying the integrity of every tier in their supply chain—not just direct suppliers. Businesses must maintain detailed traceability documentation, including material origin and supplier practice records, to demonstrate compliance, and keep tabs on sanctions and trade restrictions data.

Compliance Exposure Risks for Supply Chains

Considering that materials often pass through several intermediaries before reaching final assembly, companies sourcing from or through China—even indirectly—face UFLPA compliance risk.

Without full transparency in their supply chains, businesses may unknowingly use Xinjiang-linked inputs. Noncompliance can result in shipment delays, legal penalties, lost contracts, and reputational harm.

Common Misconceptions About UFLPA Compliance

• “We don’t source from Xinjiang.” Many companies incorrectly believe they are in the clear because their Tier 1 suppliers are outside Xinjiang, but risk often resides in upstream suppliers (Tier 2–4 and beyond). Because the UFLPA Entity List is not exhaustive, simply screening it is insufficient to proactively identify supply chain risk..
• “This only applies to apparel and solar.” Enforcement now prioritizes electronics, automotive components, agriculture, and more, but the law has no limit on scope.
• “Certificates or audits are enough.” Generic environmental, social, and governance (ESG) statements don’t satisfy CBP.
• “I’m not a U.S. company so it doesn’t affect me.” Companies selling to the U.S. market, even without physical U.S. operations, also must pay attention to this law. For instance, European or Asian automotive suppliers face substantial business risk if their shipments to U.S. automakers are detained.
• “Deeper supply chains—especially in China—are inaccessible or unknowable.” Despite the challenges associated with N-tier supply chain visibility, investment in the right tools and capabilities can create the visibility needed to materially mitigate reputational risk and stay ahead of enforcement.

Recent Trends in UFLPA Enforcement

UFLPA enforcement has escalated rapidly in recent years, both in intensity and scope.

Increased Shipment Detentions

CBP detained about 25% more shipments in 2024 than in 2023, according to Washington, D.C.,-based law firm Miller & Chevalier​. On average, 428 shipments per month were held in 2024, up from 342 per month in 2023​. November 2024 marked the highest monthly detention count on record at 648.

According to CBP’s UFLPA Dashboard, 47% of shipments detained from June 2022 to December 2024 were ultimately denied entry into the U.S.

Expanded Reach Beyond Xinjiang

A significant portion of detained shipments involve products where Xinjiang-linked materials were incorporated in third countries before being shipped to the U.S. CBP data reveals that a greater proportion of detained shipment value originated from Malaysia, Vietnam, and Thailand compared to China.

Sectors Facing Increased Scrutiny

The solar energy sector experienced significant disruption in the first year of UFLPA, causing numerous delays in U.S. solar projects. But by 2024, the number of detentions in its industrial materials category actually fell sharply​.

Today, new industries—including the automotive and aerospace sectors, particularly—have emerged as focal points for CBP scrutiny. This includes heightened investigations of electric vehicle (EV) battery materials, tires, and even drone components—many of which trace back to Xinjiang. This focus is evidenced by a dramatic 1,580% surge in automotive and aerospace shipment detentions between 2023 and 2024.

Additional expanded focus areas for CBP include:

• Electronics: Chips, printed circuit boards (PCBs), other solar components
• Apparel and textiles: Cotton and footwear
• Metals, agriculture, and renewables

Each year, the U.S. Department of Homeland Security (DHS) is required to report to Congress its strategy for implementing UFLPA. This informs CBP’s enforcement activities and highlights areas where businesses should expect increased scrutiny. As of July 2024, DHS formally prioritized additional sectors like aluminum, seafood, and polyvinyl chloride (PVC).

That said, no industry is truly immune if any input can be traced to forced labor.

Rising Concern About Compliance Exposure

As enforcement continues, compliance leaders, responsible sourcing executives, and supply chain managers are under pressure to demonstrate due diligence across increasingly complex global supply chains. Boards are seeking answers—and accountability—from supply chain and responsible sourcing executives.

Keys to Mitigating UFLPA Supply Chain Risk in 2025

Organizations that act now to build defensible compliance programs can reduce risk, avoid disruptions, and maintain access to U.S. markets. Here’s how.

Multi-Tier Supply Chain Mapping and Traceability

Go beyond Tier 1 and get visibility across your entire supply chain. Map the full supply chain from raw materials to finished goods, and identify all sourcing nodes. In addition, create traceability systems to track the specific movement of products or materials through the supply chain.

While mapping establishes the “who” of your supply chain, traceability documents the “where” and “how.” Use supply chain intelligence platforms and risk assessment tools to surface potential vulnerabilities.

Proactive Risk Identification

When CBP detains a shipment, they don’t disclose to the importer why the product was detained. That’s just one reason why it’s crucial to screen beyond inclusion on the UFLPA Entity List.

CBP leverages multiple intelligence sources—including data from Kharon—to investigate entities with potential forced labor ties, even if they haven’t been formally listed. This means that clearing the Entity List isn’t enough. Screen suppliers and sub-suppliers for hidden risk, like indirect ties to Xinjiang, flagged investors, and even loose connections to state-run labor programs.

Having access to the same open-source risk data CBP uses—via Kharon—can help you avoid ambiguity during a detention and can help stop problems before they start.

Intelligent Monitoring

UFLPA compliance is not a one-time project, but an ongoing process. Aim for early intervention before risk becomes disruption. Establish real-time alerts and automated workflows to stay ahead of policy changes, supplier developments, and enforcement trends.

Documentation and Defensibility

Maintain a documentation system that is CBP-ready at all times. It should capture:

• Bills of material
• Supplier declarations
• Certificates of origin
• Third-party audit data

Noncompliance carries substantial costs, including hefty legal fees, storage and demurrage charges, and potential lost sales. Beyond direct expenses, businesses face operational disruptions and strained supplier relationships. A 2024 report from Oritain, an organization focused on product origin verification, found that noncompliance can cost upwards of $810,000 for a single detention case.

Compliance Training and Education

Train your teams to spot red flags—then act. Sourcing, procurement, and logistics teams should learn how to identify and escalate concerns tied to geography or unknown sourcing.

Forced Labor Mitigation with Kharon

In navigating UFLPA challenges, data-driven intelligence tools are indispensable. Kharon’s data to manage forced labor risks in supply chains empowers compliance teams to:

• Screen entities and corporate networks tied to Uyghur forced labor programs
• Visualize multi-tier supply chain risk via relationship mapping
• Monitor enforcement and policy trends
• Build verifiable documentation

With Kharon’s ClearView platform, organizations can surface exposure across global operations—reducing the risk of shipment detentions, reputational fallout, and enforcement penalties.

Stay ahead of UFLPA enforcement and use Kharon to build a defensible compliance program. Learn more about Kharon’s Forced Labor solutions here.