ARTICLE
28 August 2025

DHS Adds Additional UFLPA High-Priority Sectors; Releases UFLPA 2025 Strategy Update

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On August 19, 2024, the U.S. Department of Homeland Security (DHS) announced that it would be adding steel, copper, lithium, caustic soda, and red dates to the list of high-priority sectors for enforcement under the Uyghur Forced Labor Prevention Act (UFLPA). DHS also announced the release of an update to the UFLPA enforcement strategy.
United States International Law

Learn more about this update and all things UFLPA at our upcoming forced labor webinar on Sept. 17, 2025. Register here.

On August 19, 2024, the U.S. Department of Homeland Security (DHS) announced that it would be adding steel, copper, lithium, caustic soda, and red dates to the list of high-priority sectors for enforcement under the Uyghur Forced Labor Prevention Act (UFLPA). DHS also announced the release of an update to the UFLPA enforcement strategy.

Addition of High-Priority Sectors

Under the UFLPA, DHS is tasked with identifying high-priority sectors for enforcement. A high-priority sector designation indicates that entities in the sector have a higher risk of forced labor or state labor transfer of Uyghurs and other ethnic minorities from Xinjiang.

In making the announcement of additional sectors, DHS cited each new addition's connections to forced labor risks. For example, DHS stated that steel and copper have both been government-backed investment focal points in Xinjiang. Similarly, lithium is a government-identified key sector for investment and development in Xinjiang.

UFLPA Enforcement Strategy Update

DHS serves as the chair of the Forced Labor Enforcement Task Force (FLETF). Each year, the task force updates the UFLPA's Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People's Republic of China (UFLPA Strategy). The task force is statutorily required to provide annual updates on the UFLPA Entity List, the list of products associated with certain listed entities, plans for enforcement and for identifying additional entities, and high-priority sectors.

The 2025 update highlights several accomplishments since the 2024 update, including:

  • Significant expansion of the UFLPA Entity List
  • Refinement of internal processes for expanding the UFLPA Entity List
  • Providing greater transparency to the trade community
  • Supporting the private sector's due diligence and compliance efforts
  • Protecting American industry from unfair trade practices

In the report, Christopher C. Pratt, acting DHS undersecretary for strategy, policy, and plans, reiterates that ending forced labor is "an economic and national security imperative for the United States."

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