Largest single expansion of the forced labor Entity List brings total to 187 entities and broadens CBP enforcement risk across multiple high-priority sectors.
On July 31, 2026, the Department of Homeland Security (DHS), acting on behalf of the Forced Labor Enforcement Task Force (FLETF), announced the addition of 43 Chinese companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, as well as technical updates to two existing entities. Upon publication of the accompanying Federal Register notice on August 3, 2026, the consolidated UFLPA Entity List will include 187 entities, representing a roughly 30 percent increase and the largest single expansion since the statute took effect.
Effective August 3, 2026, U.S. Customs and Border Protection (CBP) will apply UFLPA's rebuttable presumption that goods produced by the 43 newly listed entities are made in whole or in part with forced labor and therefore are prohibited from entry into the United States. CBP reports that, since UFLPA's enactment, it has already denied entry to more than 24,300 shipments under this authority, with a total value of nearly 1 billion dollars.
DHS's press release and related materials emphasize that the 43 new designations cover companies in high-priority enforcement sectors, including aluminum, apparel, copper, cotton and cotton products, and tomatoes and downstream products. The new entities are identified under UFLPA section 2(d)(2)(B)(ii) (entities working with the Xinjiang Uyghur Autonomous Region (XUAR) government to recruit, transport, transfer, harbor, or receive forced labor) and section 2(d)(2)(B)(v) (facilities and entities that source materials from Xinjiang or from persons participating in government labor transfer or similar programs using forced labor).
DHS has published entity-specific information describing the nature of each new designation and the relevant UFLPA statutory provisions. The revised consolidated UFLPA Entity List will appear as an appendix to a DHS/FLETF Federal Register notice scheduled for publication on August 3, 2026; a public inspection copy is already available. DHS continues to maintain a dedicated UFLPA portal with links to the Entity List, enforcement guidance, and compliance resources for importers.
From a practical standpoint, the expansion significantly heightens compliance risk for importers whose supply chains touch the newly designated entities or sectors that remain heavily reliant on inputs originating in or connected to Xinjiang. CBP will presume that any merchandise mined, produced, or manufactured wholly or in part by an Entity List company is inadmissible unless the importer can overcome the presumption with clear and convincing evidence of the absence of forced labor, supported by robust supply chain tracing and credible third-party documentation. In addition, CBP may scrutinize shipments further downstream in the value chain, including finished goods manufactured outside China that incorporate inputs sourced from UFLPA-listed entities.
Importers should immediately identify any direct or indirect relationships with the 43 newly listed companies and their affiliates. This includes reviewing supplier master data, purchase orders, bills of materials, and vendor declarations to confirm whether any materials or components trace back to UFLPA entities. Companies in the aluminum, apparel, copper, cotton, and tomato sectors should anticipate increased CBP targeting and be prepared to respond quickly to detention notices and requests for information or documentation.
As part of a risk-based approach, importers should consider updating supplier due diligence questionnaires, contractual representations and warranties, and audit protocols to incorporate the latest UFLPA Entity List expansions. Where exposure cannot be eliminated in the near term, importers may need to evaluate alternative sourcing strategies, build additional buffer stock to manage potential detentions, and prepare detailed evidentiary packages in advance for high-risk lanes. Training procurement, compliance, and logistics teams on UFLPA developments and CBP expectations remains critical to reducing supply-chain and enforcement risk.
Nakachi Eckhardt & Jacobson, P.C. advises importers, manufacturers, and retailers on UFLPA compliance, forced labor due diligence, and CBP enforcement, including detention challenges and administrative and judicial review. We assist clients in mapping supply chains, evaluating Entity List exposure, and developing documentation strategies that align with CBP's evidentiary expectations. If you have questions about how the July 31, 2026 UFLPA Entity List expansion may affect your imports, please contact our Forced Labor Compliance and Enforcement team.