On August 19, 2025, the Forced Labor Enforcement Task Force, chaired by the Department of Homeland Security and including agencies such as the Department of Labor, released its annual update to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China. This update, required by the Uyghur Forced Labor Prevention Act (UFLPA), outlines expanded enforcement measures to prevent goods made with forced labor—especially in the Xinjiang Uyghur Autonomous Region—from entering the U.S. market.

The Task Force has identified five new high-priority sectors for enforcement: caustic soda, copper, jujubes (red dates), lithium, and steel. These join previously designated sectors such as apparel, cotton, tomatoes, polyvinyl chloride, seafood, silica-based products, and aluminum. The selection of these sectors is based on credible evidence of forced labor risk, government investment targeting Xinjiang, and the region’s prominence in global production. The strategy encourages American companies to intensify scrutiny and due diligence in these sectors to mitigate regulatory and reputational risk.

The 2025 update also significantly expanded the UFLPA Entity List, which now includes 144 entities, up from 66 in 2024. The Task Force added 78 new entities, removed one, and made three technical corrections, reflecting streamlined processes for identifying organizations involved in forced labor. Goods produced by these entities are presumed to be made with forced labor and are prohibited from entry unless importers provide clear and convincing evidence to the contrary. The update also includes a detailed product list, ranging from textiles and apparel to chemicals, batteries, metals, agricultural goods, and electronics, providing importers with guidance on supply chain risks.

The update highlights enhanced collaboration with industry, non-governmental organizations, and international partners. The Task Force continues to hold biannual stakeholder meetings and targeted webinars (including for the seafood sector) and maintains public channels for submitting comments or recommendations on potential Entity List additions. Enforcement actions remain robust, with U.S. Customs and Border Protection examining more than 16,000 shipments valued at nearly $3.7 billion since the UFLPA rebuttable presumption took effect, and deploying tools such as detentions, exclusions, seizures, sanctions, visa restrictions, and export controls. The Task Force stated that it will continue to expand the Entity List, monitor high-priority sectors, and strengthen partnerships to ensure supply chains remain free from forced labor. DHS’s UFLPA update, coupled with CBP’s June WRO guidance, demonstrates that forced labor enforcement is accelerating and companies should address supply chain risks.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of John Brew John Brew

John Brew is the former chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office.

John has extensive experience in import and export trade regulation, collaborating with corporations, trade associations, foreign governments, and nongovernmental organizations on…

John Brew is the former chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office.

John has extensive experience in import and export trade regulation, collaborating with corporations, trade associations, foreign governments, and nongovernmental organizations on customs administration, enforcement, compliance litigation, legislation, and policy matters. He 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. John 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, customs brokerage, Section 321, drawback, foreign trade zones, duty recovery programs, import restrictions, quotas, audits, prior disclosures, penalties, investigations, Customs Trade Partnership Against Terrorism and trade compliance programs, importations under bond, the Jones Act, and vessel repairs.

Read more about John Brew
Show more Show less
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.

Read more about Pierfilippo M. NattaPierfilippo M.'s Linkedin Profile
Show more Show less
Photo of Andrew J. Schlegel 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.

Read more about Andrew J. SchlegelAndrew J.'s Linkedin Profile
Show more Show less
Related Posts
Kingtom Aluminio Defends CIT’s Forced Labor Decision
November 18, 2025
CBP Faces Legal Challenge over Exclusion of Camel Energy’s Battery Imports
October 31, 2025
CIT Vacates CBP Forced Labor Finding Against Aluminum Importer
September 25, 2025