| TRUMP ADMINISTRATION TRADE ALERT – IMPORTS | |
| HEADLINE | New Sectors Designated as High-Priority Enforcement Under UFLPA |
| DATE | August 19, 2025 |
| AGENCY | Department of Homeland Security, along with the Departments of Labor, State, Treasury, Justice, and Commerce; Customs and Border Protection; U.S. Trade Representative |
| EFFECTIVE DATE | August 19, 2025 |
| BACKGROUND | The 2021 Uyghur Forced Labor Prevention Act
("UFLPA") established a rebuttable presumption that goods
produced wholly or in part in the Xinjiang Uyghur Autonomous Region
("XUAR") of China or by an entity on the UFLPA Entity
List are made with forced labor and prohibited from importation
into the U.S. The UFLPA created the Forced Labor Enforcement Task Force ("FLETF"), which is led by DHS and adds entities and sectors to enforcement. The initial high-priority sectors for UFLPA enforcement were apparel, cotton, tomatoes, and polysilicon. In 2024, the FLETF added polyvinyl chloride (PVC), aluminum, and seafood. |
| DETAILS | The Department of Homeland Security has added 5 sectors to the
high-priority sector list for UFLPA enforcement:
This is in addition to the previously identified high-priority sectors:
A high-priority sector designation indicates that entities/goods in that sector have a higher risk of forced labor and/or sourcing from the XUAR, and indicates a higher likelihood of enforcement or inquiry from CBP. The Trump Administration has increased detentions and enforcement actions, and fewer releases, under the UFLPA:
Should importers find their shipments detained, they must either demonstrate their importation is outside the scope of the UFLPA because it has no nexus to Xinjiang or a UFLPA entity, or present substantial "clear and convincing" evidence to rebut the presumption that the detained goods are made with forced labor and demonstrate (1) that the company has a robust due diligence & compliance system, (2) that the company engages in supply chain tracing and can trace their supply chains to the raw materials, and (3) that there is no Xinjiang sourcing/forced labor used throughout the entire supply chain. |
| BASIS | Uyghur Forced Labor Prevention Act (Pub. L. 117-78) (Dec. 23, 2021); 22 U.S.C § 6901 |
| HTS/ PRODUCTS |
Products of steel, copper, lithium, caustic soda, red dates. |
| COUNTRY | China; Xinjiang Uyghur Autonomous Region |
| CITE | DHS Press Release – Trump Administration Fights for America's
Economic and National Security, Designating New Chinese Industry
Sectors as High-Priority for Enforcement under the Uyghur Forced
Labor Prevention Act | Homeland Security DHS Report to Congress – 2025 Updates to UFLPA Strategy (High-Priority Sectors) Report DHS Fact Sheet – 2025 Updates to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People's Republic of China | Homeland Security |
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