UFLPA Entity List 2026 Update: What Importers Need to Verify

The Uyghur Forced Labor Prevention Act (UFLPA) is the most operationally consequential US import compliance law of the 2020s. The rebuttable presumption that goods linked to Xinjiang or listed entities are made with forced labor places the burden on the importer to prove otherwise before customs will release. Detentions exceeded 8,000 shipments in 2025 with detained cargo valued at over 3.8 billion USD. The DHS entity list expanded in early 2026 to 116 entities, with new additions across solar, aluminum, electronics, and apparel supply chains.

This guide covers the current entity list structure, the legal mechanics of the rebuttable presumption, the documentation required to rebut, and the practical implications for mid-market importers in 2026.

What UFLPA does

The 2021 statute (Public Law 117-78) imposes a rebuttable presumption under 19 USC 1307 (the forced labor prohibition statute that has existed for decades) that any good made wholly or in part:

• In the Xinjiang Uyghur Autonomous Region (XUAR), OR
• By an entity on the DHS UFLPA Entity List, OR
• In a labor transfer program from XUAR to facilities elsewhere,

is presumed to be made with forced labor and is therefore prohibited from US import.

The presumption is rebuttable: the importer can prove the contrary with clear and convincing evidence. In practice, the rebuttal standard is high and the success rate is low (around 12 percent of rebuttal attempts).

The 2026 entity list expansion

DHS added 26 entities during 2025 and 8 more in early 2026. The current list (116 total) breaks down by industry:

Notable 2026 additions include several aluminum smelters in the labor transfer program (not located in Xinjiang but employing transferred Xinjiang workers), three additional polysilicon producers, and the first EV battery material entities (cathode active material producers using Xinjiang-routed inputs).

The full list is maintained at the DHS Forced Labor Enforcement Task Force page.

What CBP does at the border

When a shipment of a CBP-priority commodity arrives, CBP performs an initial review. Priority commodities currently include cotton apparel, polysilicon solar panels, aluminum products, tomato products, electronics with semiconductor or battery content. For these commodities, CBP holds the shipment pending importer documentation of supply chain origin.

The importer receives a Notice of Detention (CBP Form 4647) listing the reason for detention. Most UFLPA detentions cite either:

• Specific listed-entity match in the shipment supply chain.
• High-risk commodity from a region where listed entities operate, requiring supply chain trace.

The importer has 30 days to respond. Failure to respond results in seizure under 19 USC 1595a.

What rebuts the presumption

CBP published the "UFLPA Importer Guidance" document in 2022 and updated it in 2025. The document specifies the documentation expected:

1. Production records for the entire supply chain, traced from the imported good back to the raw material extraction or harvest.
2. Ground transportation logs showing the physical movement of raw materials, intermediate products, and finished goods.
3. Employment records for every tier of the supply chain showing names, wages, and labor terms of the workforce.
4. Independent audits by an approved third-party auditor showing absence of forced labor at every tier.
5. Origin certificates for the raw inputs from the country and facility where the raw input was produced.

The rebuttal must show that no input at any tier was sourced from a listed entity or from XUAR. A single missing tier or a single listed-entity input in the supply chain fails the rebuttal.

The 2025 to 2026 detention pattern shows that even importers with extensive documentation often fail because their suppliers cannot or will not provide the deep-tier trace.

Worked example: solar panel import

A US importer brings in 5 MW of solar panels from a Malaysian assembly plant, manufactured by a non-listed entity. The polysilicon used in the cells is sourced from a Chinese producer not on the entity list.

CBP detains the shipment for UFLPA review on the priority-commodity (solar) basis.

The importer must trace the polysilicon back to the metallurgical-grade silicon (MGS) source. The MGS sourcing reveals that one of two suppliers feeding the polysilicon producer is a Xinjiang-region facility. CBP rules the rebuttal fails. The 5 MW of panels (approximately 2 million USD value) is detained, exported, or destroyed at the importer's option.

The financial impact: 2 million USD of inventory plus carrying cost during the 90 to 180 day review, plus the operational disruption to the importer's downstream solar installation pipeline.

Practical operational responses

Mid-market importers have adopted several practices to reduce UFLPA exposure:

1. Pre-screen suppliers against the entity list at PO stage. Before placing an order, run the supplier name through the DHS list. If matched, switch supplier.
2. Require traceability documentation as a contract condition. Suppliers must provide tier-2 and tier-3 source documentation up-front, not after-the-fact when CBP detains.
3. Third-party traceability audits. Engage firms like ELEVATE, Bureau Veritas, or SGS to audit the supply chain annually. The audit report becomes part of the rebuttal package.
4. Substitute high-risk inputs. For polysilicon, source from US or Korean producers (TWC Solar, OCI Solar). For cotton, source from Brazil, Australia, US, or Egypt rather than Chinese suppliers with unclear cotton sourcing. For aluminum, prefer Canadian or US smelted ingot.
5. Free zone routing as risk mitigation, not avoidance. Goods can be held in FTZ pending documentation, but the FTZ does not exempt the goods from UFLPA. The same documentation requirement applies before release into the customs territory.

Documentation that survives a CBP detention

The shortest documentation package that has succeeded in rebuttals:

• Supplier name and address, with screenshot of DHS list match-check at PO date.
• Bill of materials per imported article with HTS line and per-input source.
• Mill or production records for each input tier traced back to extraction or harvest.
• Independent third-party audit report dated within 12 months of the import, covering the supplier's facility and labor practices.
• Government-issued production licenses or certifications from each upstream facility.
• Sworn statement from the importer attesting to the truth of the documentation.

Total documentation: typically 80 to 300 pages for a single shipment of a complex commodity. Audit cost: 5,000 to 50,000 USD per supplier per year.

Run your UFLPA risk screen now

The LandedFees calculator includes a UFLPA entity-list match check for any importer and supplier name. If either matches, the engine flags the high-risk-commodity status and the documentation requirements before the shipment is filed.

Run a UFLPA risk check

Citations

• Uyghur Forced Labor Prevention Act (Public Law 117-78): https://www.dhs.gov/uflpa
• DHS UFLPA Entity List: https://www.dhs.gov/uflpa-entity-list
• CBP UFLPA Importer Guidance: https://www.cbp.gov/trade/forced-labor/UFLPA
• 19 USC 1307 (forced labor prohibition): https://www.law.cornell.edu/uscode/text/19/1307
• DHS Forced Labor Enforcement Task Force: https://www.dhs.gov/forced-labor-enforcement-task-force