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Forced Labor + WROs

Combating Forced Labor

Uyghur Forced Labor Prevention Act (UFLPA)


We know what you’re thinking…not another football league spinoff. Fear not because the UFLPA takes on a much more heroic role in our society. Forced labor generates an estimated $150 billion (USD) in profits annually and affects over 27 million laborers (about the population of Texas). The hero wrapped in a red cape here to save millions of laborers is none other than the Uyghur Forced Labor Prevention Act.

The UFLPA is intended to address and counter forced labor and human rights violations in the Xinjiang Uygur Region of China, where there have been reports of mass arbitrary detention, forced labor, and other human rights abuses against Uyghurs and other ethnic minority groups.

The act proposes several measures to combat forced labor and ensure that goods produced using forced labor in the XUAR are not allowed into the United States. Some of the key provisions may include:

  1. Import Restrictions: The act may require the U.S. Customs and Border Protection to enforce restrictions on imports of goods that are produced in whole or in part using forced labor in the XUAR. This is aimed at preventing such goods from entering the U.S. market.
  2. Public Disclosures: Companies that do business in or with the XUAR may be required to disclose information about their supply chains to ensure transparency and identify any potential involvement in forced labor practices.
  3. Export Controls: The act may enable the U.S. government to impose export controls on technologies and goods that could be used in surveillance and repression in the XUAR.
  4. Sanctions: The UFLPA may empower the U.S. government to impose sanctions on individuals, entities, and officials involved in human rights abuses and forced labor practices in the XUAR.

It’s important to note that the specifics of the UFLPA may vary depending on the version and amendments of the legislation. You can also view our UFLPA resources.

UFLPA Enforcement Stats


UFLPA Enforcement Stats

The act has received increasing attention in previous years with the number of entries targeted—since 2020 alone, the entries have catapulted by a whopping 500%. But, it’s not without good reason, as championing these fair labor practices aligns with a future in which every worker is treated with dignity and respect. 

UFLPA Updates

View UFLPA Updates

Date Details 
08/01/2023 The Forced Labor Enforcement Task Force (FLETF) has published an updated UFLPA Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China
12/11/2023 Three new China – Based Companies added to Uyghur List The DHS (Department of Homeland Security) announced on Dec. 8 the addition of three China-based companies to the Uyghur Forced labor Prevention Act (UFLPA). The total number of restricted companies is now 30. Effective Dec. 11, goods produced by COFCO Sugar Holding Co. Ltd, Sichuan Jingweida Technology Group Co., Ltd, and the Anhui Xinya New Materials Co., Ltd will be restricted from entering the United States. The UFLPA, signed into law by President Biden in Dec. 2021, prohibits goods from being imported into the U.S. that are either produced in Xinjiang, or by entities identified on the UFLPA Entity List, unless the CBP determines that the goods were not produced with forced labor. CBP began enforcing the UFLPA in June 2022 and since then, the agency has reviewed more than 6,000 shipments valued at more than $2 billion.  


Best Practices for Combating Forced Labor

Want to take these tips with you? Just fill out our Forced Labor form and download this free guide to stay on the right side of the fight against forced labor!

Best Practices for Combating Forced Labor




Withold Release Orders (WROs)

Forced Labor Violations have really come to light in the last several years. A Withhold Release Order is issued by the respective commissioner to prevent goods being made with forced labor from entering the U.S. Commerce. To learn more about Forced Labor, check out our blog.

WROs instruct Customs Officers to prevent imports from entering the U.S. due to “reasonable but not conclusive” evidence that forced labor was used in the overseas production of goods. Think Civil vs. Criminal cases when it comes to court – they have completely different standards of guilt. This is very important for manufacturers to be aware of as even the materials used in production could cause an issue.

For example, if you purchase leather made as a result of forced labor and use it for the production of purses, you could be on the hook due to the origin of said leather! 

China

China
#DateMerchandiseEntitiesStatusStatus Notes
3506/23/2021Silica-based productsHoshine Silicon Industry Co. Ltd. and SubsidiariesActiveReference Hoshine Frequently Asked Questions | Press Release
3401/13/2021Cotton, Tomatoes, and Downstream ProductsXinjiang Uyghur Autonomous Region (XUAR)ActiveReference XUAR Frequently Asked Questions | Press Release
3311/30/2020Cotton and Cotton ProductsXinjiang Production and Construction Corporation (XPCC) and its subordinatesActivePress Release
329/8/2020Computer PartsHefei Bitland Information Technology Co., Ltd.ActivePress Release
319/8/2020Cotton and Processed CottonXinjiang Junggar Cotton and Linen Co., Ltd.ActivePress Release
309/3/2020ApparelYili Zhuowan Garment Manufacturing Co., Ltd. and Baoding LYSZD Trade and Business Co., Ltd.ActivePress Release
298/25/2020All ProductsNo. 4 Vocational Skills Education Training Center (VSETC)ActivePress Release
288/25/2020Hair ProductsLop County Hair Product Industrial ParkActivePress Release
278/11/2020GarmentsHero Vast GroupActivePress Release
266/17/2020Hair ProductsLop County Meixin Hair Products Co., Ltd.ActivePress Release
255/1/2020Hair ProductsHetian Haolin Hair Accessories Co., Ltd.ActivePress Release
249/30/2019All GarmentsHetian Taida Apparel Co., Ltd.ActivePress Release
233/5/2018All ProductsHuizhou Mink Industrial CO. LTD.Active
229/16/2016Peeled GarlicHongchang Fruits & Vegetable Products Co., Ltd.Active
215/20/2016Stevia and its DerivativesInner Mongolia Hengzheng Group Baoanzhao Agricultural and Trade LLCActive
203/29/2016Soda Ash, Calcium Chloride, and Caustic SodaTangshan Sanyou Group and its SubsidiariesPartially Active<10/12/2016
CBP removed viscose/rayon fiber from the order
1910/6/1995Malleable Iron Pipe FittingsTianjin Malleable Iron Factory, a/k/a Tianjin Tongbao Fittings Company, a/k/a Tianjin No. 2 Malleable Iron Plant, a/k/a Tianjin Secondary Mugging Factory, a/k/a Tianjin No. 2 PrisonActiveSee China Finding below.
184/27/1995TeaNanhu Tree Farm, Zhejiang Sanmei Tea Co., Ltd.; Imaizumi Tea Manufacturing & Trading Co., Ltd. (of Nagoya, Japan)Active
1712/21/1994Artificial FlowersGuangzhou No. 1 Reeducation-Through-Labor Camp, a/k/a Guangdong Province No. 1 Reeducation-Through-Labor Camp; Kwong Ngai Industrial CompanyActive
169/3/1993Rubber Vulcanization AcceleratorsShenyang Xinsheng (New Life) Chemical Works, a/k/a Shenyang Dongbei Assistant Agent Main Factory, a/k/a Xinsheng Chemical Factory, a/k/a Shenyang No. 1 Laogai Detachment, a/k/a Shenyang Reform Through Labor Second Reform DivisionActive
159/1/1993Rubber Gloves, Condoms, Rubber Raincoats, and Rubber FootwearShenyang New Life Rubber Factory, a/k/a Shenyang Xingsheng (or Xinsheng) (New Life) Rubber Plant, a/k/a Shenyang No. 2 Laogai Detachment, a/k/a Shenyang Dabei Prison, a/k/a Shenyang Model PrisonActive
148/6/1993HoistsWuyi Machinery Plant, a/k/a Zhejiang Light Duty Lifting Machinery Factory China, a/k/a Zhejiang Province No. 1 PrisonActive
137/8/1993HoistsWulin (or Wuling) Machinery Works, a/k/a Hangzhou Wulin Machinery Plant, a/k/a Hangzhou Wulin Machinery Works, a/k/a Zhejiang Province No. 4 PrisonActive
128/14/1992AsbestosHsin Kang Asbestos Mine, a/k/a Sichuan (Szechuan) Pin Chiang Enterprise CompanyActive
118/3/1992Electric Fans and Zinc-Coated WireSichuan (Szechuan) Xinsheng (New Life) Labor Factory, a/k/a Xinsheng (New Life) Labor FactoryActive
107/17/1992Sulfuric (Sulphuric) AcidDa Wei Chemical FactoryActive
97/15/1992Drilling MachinesZi Gong Machinery Factory, a/k/a Zigong Machinery Factory, a/k/a Sichuan (Szechuan) Zigong Labor Reform DetachmentActive
87/15/1992Auto Parts and MachineryYa An Auto Parts Factory, a/k/a Sichuan (Szechuan) Bin-Jiang Enterprises CompanyActive
76/26/1992TeaMiao Chi Tea FarmActive
66/26/1992Cast Iron ItemsWang Tsang Coal and Iron FactoryActive
55/22/1992Sheepskin and LeatherQinghai Hide & Garment Factory, a/k/a Qinghai Leather and Wool Bedding and Garment Factory, a/k/a Qinghai Fur and Cloth FactoryActiveSee China Finding below.
42/25/1992Galvanized PipeShandong Laiyang Heavy Duty Machinery FactoryActive
312/2/1991Machine PressesXuzhou Forging and Pressing Machine WorksActiveSee China Finding below.
211/14/1991Diesel EnginesYunnan Machinery, a/k/a Golden Horse (JinMa) Diesel Factory, a/k/a Yunnan 1st PrisonActiveSee China Finding below.
111/6/1991Planing MachinesXiang-Yang Machinery PlantActive

Democratic Republic of the Congo

Democratic Republic of the Congo
#DateMerchandiseEntitiesStatusStatus Notes
19/30/2019GoldArtisanal Small MinesPartially Active5/28/2023
CBP has removed ASM DRC gold imported by the Chambers Federations from the order.

Dominican Republic

Dominican Republic
#DateMerchandiseEntitiesStatusStatus Notes
111/23/2022Raw sugar and sugar-based productsCentral Romana Corporation LimitedActivePress Release

India

India
#DateMerchandiseEntitiesStatusStatus Notes
111/23/1999Beedie Cigarettes and Other Tobacco ProductsMangalore Ganesh Beedie WorksActivePress Release
207/29/2022GarmentsNatchi Apparel (P) Ltd.Inactive09/07/2022:
CBP marks order as inactive

Japan

Japan
#DateMerchandiseEntitiesStatusStatus Notes
106/12/1994Video Games and Connector Plugs ThereofFuchu Prison; Union Kogyo Co., Ltd.ActivePress Release

Malawi

Malawi
#DateMerchandiseEntitiesStatusStatus Notes
111/1/2019TobaccoTobacco produced in Malawi and products containing tobacco produced in MalawiPartially ActiveCBP has removed tobacco and products containing tobacco produced in Malawi from the order that are produced by the following:
  • 06/03/2020: Alliance One International removed from the order

  • 07/31/2020:
    Limbe Leaf Tobacco Company Limited (LLTC) removed from the order, 07/31/2020.
  • 05/21/2021:
    Premium Tobacco Malawi Lt (PTML) removed from the order

Malaysia

Malaysia
#DateMerchandiseEntitiesStatusStatus Notes
61/28/2022Disposable GlovesYTY Industry Holdings Sdn Bhd (YTY Group), including YTY Industry Sdn Bhd, Green Prospect Sdn Bhd, and GP LumutInactiveInactive by Memo from Commissioner dated 02/08/2023. Press Release
512/20/2021Disposable GlovesBrightway Holdings Sdn Bhd, Laglove (M) Sdn Bhd, and Biopro (M) Sdn Bhd (collectively, Brightway Group)ActivePress Release
411/04/2021Disposable GlovesSmart GloveInactiveInactive by Memo from Commissioner dated 04/26/2023. Press Release
310/21/2021Disposable GlovesMaxter Glove Manufacturing Sdn Bhd, Maxwell Glove Manufacturing Berhad, and Supermax Glove ManufacturingActivePress Release
3212/30/2020Palm Oil & Palm Oil ProductsPalm Oil & Palm Oil
ProductsPalm Oil & Palm Oil Products
Sime Darby Plantation Berhad and its subsidiaries and joint venturesInactiveInactive by 88 FRN 7451 effective 02/03/2023. | Press Release
19/30/2020Palm Oil & Palm Oil ProductsFGV Holdings Berhad and its subsidiaries and joint venturesActivePress Release

Mexico

Mexico
#DateMerchandiseEntitiesStatusStatus Notes
110/21/2021Fresh TomatoesAgropecuarios Tom S.A. de C.V. and Horticola Tom S.A. de C.V. and their subsidiariesActivePress Release

Nepal

Nepal
#DateMerchandiseEntitiesStatusStatus Notes
17/21/1998Carpets, Hand-Knotted WoolKumar Carpet Pvt., Singhe Carpet Pvt., Ltd., Norsang Carpet Industries Pvt., Ltd., Annapurna Carpet, Everest Carpet, Valley Carpet, and K.K. Carpet Industries; Kathmandu.Partially Active.
  • 10/6/1998.
    Everest Carpet, K.K. Carpet Industries; and Norsang Carpet Industries Pvt., Ltd. removed from the order.

  • 7/23/2021:
    Annapurna Carpet removed from the order

Turkmenistan

Turkmenistan
#DateMerchandiseEntitiesStatusStatus Notes
105/18/2018CottonAll Turkmenistan Cotton or products produced in whole or in part with Turkmenistan cotton.Active

Zimbabwe

Zimbabwe
#DateMerchandiseEntitiesStatusStatus Notes
19/30/2019Artisanal Rough Cut DiamondsMarange Diamond FieldsActivePress Release

Fishing Vessels

Fishing Vessels
#DateMerchandiseEntitiesStatusStatus Notes
508/04/2021SeafoodFishing Vessel: Hangton No. 112ActivePress Release
405/26/2021SeafoodFishing Vessels owned by Dalian Ocean Fishing Co. Ltd.ActivePress Release
312/31/2020SeafoodFishing Vessel: Lien Yi Hsing No. 12ActivePress Release
28/18/2020SeafoodFishing Vessel: Da WangActivePress Release
15/11/2020SeafoodFishing Vessel: Yu Long No. 2ActivePress Release