The Uyghur Forced Labor Prevention Act (UFLPA) enforcement has intensified, with the U.S. Department of Homeland Security (DHS) adding 37 China-based companies to the Entity List for alleged involvement in forced labor. Among them, 26 operate in the cotton sector, posing significant compliance risks for apparel and textile importers. Businesses sourcing from these entities may face shipment detentions and increased scrutiny.
Why These Companies Were Added
DHS identified Huafu Fashion Co., Ltd. and 25 of its subsidiaries as key players in the cotton industry linked to forced labor in the Xinjiang Uyghur Autonomous Region (XUAR). Huafu operates a vertically integrated supply chain, covering cotton cultivation, processing, and textile production. Most of its subsidiaries are in XUAR, while a few operate in Zhejiang Province.
By adding these companies to the UFLPA Entity List, the U.S. government aims to prevent the import of goods made with forced labor. Apparel businesses sourcing cotton from these companies could face strict enforcement actions, including shipment detentions and financial penalties.
Enforcement in the Apparel Industry
The apparel, footwear, and textile industries have been a major focus of UFLPA enforcement. In December 2024, U.S. Customs and Border Protection (CBP) processed over 2.8 million entry summaries, valued at more than $290 billion. Of these, 1,404 shipments—worth $18.7 million—were flagged for potential forced labor links.
Key statistics from UFLPA enforcement in apparel and textiles:
- Total shipments detained: 1,996 (up from 1,963 the previous month)
- Shipments denied entry: 1,274 (63.8%)
- Shipments released after review: 649 (32.5%)
- Shipments still pending: 73
- Total shipment value affected: $90.42 million
With nearly 2,000 shipments held at U.S. ports, it’s clear that enforcement is ramping up. Apparel brands and retailers must ensure they have verifiable proof that their supply chains are free from forced labor to avoid delays, penalties, and reputational damage.
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Challenges for Importers
The law requires companies to trace their entire supply chain and provide clear documentation proving their products are not linked to forced labor. Failure to do so can lead to significant business disruptions, including shipment seizures and financial losses.
The complexity of global textile supply chains makes this task challenging. Cotton may pass through multiple processing facilities before becoming fabric, making it difficult to track its exact origin. Companies relying on Chinese cotton must take proactive steps, such as third-party audits, supplier certifications, and enhanced due diligence, to stay compliant.
The Future of UFLPA Enforcement
This latest expansion of the UFLPA Entity List signals the U.S. government’s commitment to strict enforcement. DHS has stated that it will continue strengthening UFLPA measures and increasing detentions at ports. Importers must adapt to these evolving regulations or risk serious consequences.
As the U.S. continues to crack down on forced labor, apparel and textile companies must rethink their sourcing strategies. Strengthening compliance efforts now will be crucial to navigating future trade restrictions and maintaining market access.
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