On November 22, 2024, the Department of Homeland Security (DHS) updated the Uyghur Forced Labor Prevention Act (UFLPA) Entity List to add 29 companies based out of the Peoples Republic of China bringing the total number of listed companies to 107. As we previously posted here and here, companies included on the UFLPA Entity List are effectively barred from importing goods into the United States. U.S. Customs will apply a “rebuttable presumption” that goods imported from listed entities are produced using forced labor in violation of U.S. law.
The majority of companies added to the Entity List are in the agricultural sector. However, two of the new entities, Xinjiang Zhonghe Co., Ltd., (also known as Xinjiang Joinworld Co., Ltd.) and Xinjiang Nonferrous Metals Industry Group Co., Ltd., may provide goods or raw materials used in renewable projects. In its press release announcing the additions to the Entity List, DHS again urged U.S. companies to review and take responsibility over their foreign supply chains and ensure compliance with the UFLPA.
If you have any questions about the latest guidance from DHS or about supply chain traceability and compliance issues generally, please do not hesitate to reach out to Monica Dozier and Aman Kahlon.