Supplier & Contractor Management
Entities on the UFLPA Entity List (2025)
Shipments stopped by CBP since enforcement began
Denial rate for China-origin detained shipments (FY 2025)
Regulation Overview
The Uyghur Forced Labor Prevention Act is the primary U.S. law prohibiting imports of goods produced with forced labor connected to China's Xinjiang Uyghur Autonomous Region. For supply chain and compliance teams, UFLPA creates a rebuttable presumption that any goods mined, produced, or manufactured wholly or in part in Xinjiang—or by any entity on the UFLPA Entity List—are prohibited from U.S. importation.
The burden falls entirely on the importer. To release detained goods, importers must provide "clear and convincing evidence" that no forced labor was involved—the highest evidentiary standard in civil law. CBP has examined over 16,700 shipments valued at nearly $3.7 billion since enforcement began, denying entry to more than 10,000.
UFLPA compliance requires multi-tier supply chain tracing documentation—origin certificates, supplier attestations, production records, and material flow evidence—from every supplier in your chain. When CBP detains a shipment, you have days to respond with evidence or lose the goods.
Key Components / Sub-Frameworks
U.S. importers of record for any goods with potential Xinjiang-region inputs
Companies sourcing raw materials processed or refined in China
Manufacturers importing components containing cotton, polysilicon, metals, or chemicals
Non-U.S. exporters selling into the U.S. market through U.S. importers
Companies assembling products in third countries using China-sourced inputs
Distributors and retailers importing finished goods with multi-tier supply chains
Key Thresholds
CBP doesn't just look at your Tier 1 suppliers. A detained shipment requires origin evidence through every production tier—smelters, refiners, cotton gins, chemical processors. Your Tier 1 supplier says the aluminum is "not from Xinjiang." CBP wants the smelter certificate, refinery records, and material flow documentation. You have none of it.
CBP detains your shipment at the port. You have 30 days to compile "clear and convincing evidence" across 4 production tiers and 8 suppliers. Your production line is stopped. Your customer is waiting. Three suppliers are unresponsive. One provides documents in Mandarin. Day 29: your evidence package is incomplete. Day 31: CBP denies entry.
FLETF's 2025 strategy expansion means steel, copper, lithium, aluminum, and caustic soda are now high-priority sectors. Your automotive parts contain aluminum castings sourced through a Malaysian intermediary from a Chinese smelter. The finished goods ship from Mexico. CBP still detains them—because the raw material traces back to a Xinjiang-linked processor.
"Clear and convincing evidence" is the highest civil evidentiary standard. Standard supplier questionnaires and self-declarations are insufficient. CBP expects production records, transaction documents, shipping records, and independent verification. Manual evidence assembly across global supply chains at this standard is unsustainable.
Certivo In Action
UFLPA Workflow
Electronics Manufacturing
Pain Point
Polysilicon in solar panels; PCBs; chip packaging; battery materials
Automotive Manufacturing
Pain Point
Aluminum castings; steel components; lithium batteries; tire materials
Industrial & Heavy Equipment
Pain Point
Steel and copper inputs; caustic soda in processing; PVC components
Aerospace & Defense
Pain Point
Specialty metals; critical mineral supply chains; government contract requirements
Energy & Infrastructure
Pain Point
Solar polysilicon; wind turbine components; battery storage materials
Consumer Goods
Pain Point
Cotton and textile inputs; tomato products; high SKU count supply chains
Chemical Manufacturing
Pain Point
Caustic soda; PVC; silica-based products; chemical intermediaries from Xinjiang
Construction Materials
Pain Point
Steel, aluminum, and PVC in building products; government procurement requirements
80% Reduction in Compliance Labor
CORA collects, parses, and validates supplier origin evidence automatically. Your team focuses on risk decisions—not chasing sub-tier documentation across global supply chains.
3 Days to Detention Response
Generate complete, "clear and convincing" evidence packages in days—not the weeks of manual compilation that result in denied shipments and lost goods.
Real-Time Entity List Screening
When FLETF adds entities or expands high-priority sectors, Certivo rescreens your entire supply chain instantly. Know your exposure before CBP targets your shipment—not after.
Key Statistics
Frequently Asked Questions
What goods are covered by UFLPA?
UFLPA applies to all goods mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of China, or by any entity on the UFLPA Entity List. This includes finished goods, raw materials, and components at any production tier. High-priority enforcement sectors include cotton, polysilicon, tomatoes, seafood, aluminum, PVC, steel, copper, lithium, caustic soda, silica-based products, and red dates. Certivo screens your supply chain against all 144 listed entities and 12 high-priority sectors.
What happens when CBP detains a shipment under UFLPA?
When CBP detains a shipment, the importer must provide "clear and convincing evidence" that the goods were not produced with forced labor. This is the highest civil evidentiary standard—standard questionnaires and self-declarations are insufficient. CBP expects multi-tier supply chain tracing, production records, transaction documents, and independent verification. CORA generates pre-structured detention response packages aligned with CBP's Operational Guidance.
How does Certivo handle the "once an article, always an article" threshold for UFLPA?
UFLPA applies to goods produced "wholly or in part" in Xinjiang. Even a small component containing Xinjiang-origin materials triggers the rebuttable presumption for the entire shipment. Certivo maps material flows at every production tier—from raw material to finished product—so you can identify exposure before goods reach the U.S. port.
Does Certivo support UFLPA alongside other forced labor regulations?
Yes. Certivo validates supplier origin evidence against UFLPA, EU CSDDD, German LkSG, UK Modern Slavery Act, and Conflict Minerals requirements simultaneously. One supplier submission, one origin tracing campaign, and multi-framework validation eliminate duplicate collection efforts.
How does Certivo track UFLPA Entity List changes?
Certivo maintains real-time sync with the UFLPA Entity List as published by FLETF. When new entities are added, CORA automatically rescreens your entire supplier base using fuzzy matching for name variations, aliases, and subsidiaries. Affected products and supply chain connections are flagged immediately—before your next shipment is at risk.