The U.S. Department of Homeland Security (DHS) has announced the addition of 29 companies based in the People’s Republic of China (PRC) to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List.

The updated list now includes a total of 107 entities, with the newly added companies operating in the food processing and metals sectors. Food processing firms are involved in activities such as planting, harvesting, production, processing, trade, and scientific research and development. Meanwhile, metals sector companies are engaged in mining, smelting, processing, product manufacturing, sales, and related research and development.

All 29 companies will be subject to a rebuttable presumption that their goods are produced using forced labor. This includes the sourcing of materials from the Xinjiang Uyghur Autonomous Region (XUAR) or collaborating with the regional government to recruit, transport, transfer, harbor, or receive members of persecuted groups in the XUAR.

The presumption takes effect on November 25, 2024.

Tags: Department of Homeland Security, FLETF, Forced Labor, UFLPA
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Photo of John Brew John Brew

John Brew is the co-chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office. He has extensive experience in import and export trade regulation, and he regularly advises corporations, trade associations, foreign governments, and non-governmental organizations…

John Brew is the co-chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office. He has extensive experience in import and export trade regulation, and he regularly advises corporations, trade associations, foreign governments, and non-governmental organizations on matters involving customs administration, enforcement, compliance, litigation, legislation and policy.

John represents clients in proceedings at the administrative and judicial levels, as well as before Congress and the international bureaucracies that handle customs and trade matters. He advises clients on all substantive import regulatory issues handled by U.S. Customs and Border Protection and Immigration and Customs Enforcement, such as classification, valuation, origin, marking, tariff preference programs, other agency regulations, admissibility, import restrictions, quotas, drawback, audits, prior disclosures, penalties, investigations, Importer Self Assessment and Customs-Trade Partnership Against Terrorism programs, importations under bond, the Jones Act, vessel repairs, and foreign trade zone matters.

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Photo of Pierfilippo M. Natta Pierfilippo M. Natta

Pierfilippo M. Natta (“Pier”), is an associate in Crowell’s International Trade Law practice. He focuses on assisting clients with complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier works on developing…

Pierfilippo M. Natta (“Pier”), is an associate in Crowell’s International Trade Law practice. He focuses on assisting clients with complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier works on developing Business and Human Rights legal guidance for clients and his practice covers a global reach including US, EU and Asia. His investigatory work has primarily focused on South-East Asia.

Pier applies his international trade knowledge to help clients identify manage and remediate risks. He has advised U.S. and global companies on developing programs specific to UN, US, and EU sanctions. More recently, Pier and the Crowell team are working to develop Crowell’s Business and Human Rights sub-practice which includes Crowell’s anti-forced labor investigatory work.

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Andrew J. Schlegel

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

…

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Andrew also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Prior to joining Crowell & Moring, Andrew worked as an intern at SAP’s Government Affairs Business Development Team in Berlin, Germany. There, he analyzed the effects of regulatory changes on SAP business operations and expansion opportunities. Before this, he completed an internship at the International Trade Administration’s Office of Energy and Environmental Industries. While there, he developed the U.S. Energy Trade Dashboard, an interactive data visualization tool for use by professionals and researchers to analyze how energy supply chains have developed.

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