On January 14, 2025, the Department of Homeland Security (DHS) announced the addition of 37 China-based entities to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. DHS cited these entities’ alleged connections to sourcing material and forced labor in the Xinjiang Uyghur Autonomous Region (XUAR) as reasons for their addition.

This batch of entities represents the largest addition to the UFLPA Entity List so far, and it brings the total number of entities on the list to 144. The Biden administration signed the UFPLA into law in 2021. UFLPA established a rebuttable presumption that prohibits goods made in whole or in part in the XUAR from entering the U.S. To date, U.S. Customs and Border Protection (CBP) has reviewed over 12,600 shipments under UFLPA, with an estimated value of $3.68 billion.

Of the 37 newly added entities, 26 entities come from the cotton sector. These 26 entities comprise of Huafu Fashion Co., one of the largest textile manufacturers in the world, and 25 of its subsidiaries. The additions also include Zijin Mining Group Co., a large supplier of critical minerals, and its subsidiaries. The remaining added entities comprise of companies in the solar energy industry and suppliers that allegedly source polysilicon from the Xinjiang region.

The additions to the list are effective January 15, 2025.

Crowell & Moring, LLP continues to monitor developments in the customs and trade remedies space and their potential impact on businesses and customers going forward.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
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.

Photo of Ivy Xun Ivy Xun

Ivy Xun is an international trade analyst in Crowell & Moring’s Washington, D.C. office. She provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative and U.S. Customs and Border Protection. She…

Ivy Xun is an international trade analyst in Crowell & Moring’s Washington, D.C. office. She provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative and U.S. Customs and Border Protection. She 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. Ivy also supports unfair trade investigations, including antidumping and countervailing duty investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission.