The UFLPA Entity List is the single most important document for US importers sourcing from China.
If your supplier—or anyone in your supply chain—appears on this list, your goods face automatic scrutiny at US ports.
Getting flagged means detention, documentation demands, and potentially losing your entire shipment.
This guide breaks down everything you need to know about the Entity List: who’s on it, why they’re listed, and how to protect your business.
What is the UFLPA Entity List?
The UFLPA Entity List is maintained by the Department of Homeland Security (DHS) Forced Labor Enforcement Task Force.
It identifies companies connected to forced labor in the Xinjiang Uyghur Autonomous Region of China.
Under the Uyghur Forced Labor Prevention Act, any goods with connections to listed entities face a “rebuttable presumption” of forced labor.
Translation: Your goods are presumed guilty until you prove otherwise.
Types of Entities on the List
Companies get listed for four main reasons:
- Mining, producing, or manufacturing goods in Xinjiang using forced labor
- Working with the Xinjiang government on labor transfer programs
- Exporting products made by other listed entities
- Being owned or controlled by listed entities
Who is Currently on the UFLPA Entity List?
As of 2026, the list includes entities across several high-risk sectors.
Polysilicon and Solar Companies
The solar industry faces intense scrutiny because Xinjiang produces approximately 45% of the world’s polysilicon.
- Hoshine Silicon Industry Co., Ltd. – Major silicon producer
- Xinjiang Daqo New Energy Co., Ltd. – Polysilicon manufacturer
- Xinjiang East Hope Nonferrous Metals Co., Ltd. – Metals and silicon
- Xinjiang GCL New Energy Materials Co., Ltd. – Solar materials
If you import solar panels, these names should be on your radar.
Cotton and Textile Companies
Cotton is ground zero for UFLPA enforcement. Xinjiang produces 85% of China’s cotton and 20% of global supply.
- Xinjiang Production and Construction Corps (XPCC) – The biggest name on the list
- Lop County Hair Product Industrial Park
- Lop County Meixin Hair Products Co., Ltd.
- Multiple cotton producers and textile mills
Tomatoes and Agriculture
- Xinjiang Guannong Tomato Products Co., Ltd.
- Sun Maid (Xinjiang) Food Co., Ltd.
Government Labor Programs
- XPCC and its subsidiaries
- Xinjiang regional government labor transfer programs
The full list is available on the DHS UFLPA Entity List page.
How Entities Get Added to the List
The Forced Labor Enforcement Task Force follows a structured process:
- Research and investigation into potential forced labor connections
- Evidence gathering from public sources, government agencies, and NGO reports
- Interagency review involving CBP, State Department, and other agencies
- Federal Register publication with opportunity for public comment
- Final listing decision
New entities are added regularly. In 2025 alone, DHS added over a dozen new companies to the list.
What Happens If Your Supplier is on the Entity List?
If CBP identifies a connection between your shipment and a listed entity:
- Your goods get detained at the port
- You receive a detention notice with 5 days to respond
- You have 30 days to provide evidence rebutting the forced labor presumption
- CBP reviews your evidence and decides: release, exclude, or seize
The burden of proof is on you. Without proper documentation, your goods won’t enter the US.
The Real Cost of Entity List Connections
- Port storage fees (often $500-2,000+ per day)
- Delayed customer deliveries
- Contract penalties
- Potential loss of entire shipment value
- Damaged supplier and customer relationships
How to Screen Suppliers Against the Entity List
Proactive screening is your best defense.
Manual Screening
You can download the Entity List from DHS and manually check supplier names.
Problems with this approach:
- Chinese company names have multiple transliterations
- The list updates frequently
- Subsidiary relationships aren’t obvious
- Time-consuming for multiple suppliers
Automated Screening
Tools like VettedImport automate the process:
- Match against multiple name variations and aliases
- Get alerts when the list updates
- Screen all supply chain participants, not just direct suppliers
- Generate documentation for CBP requests
Beyond Direct Suppliers: The Hidden Risk
Here’s what many importers miss:
Your direct supplier might be clean, but their suppliers might not be.
Example: A garment factory in Vietnam isn’t on the Entity List. But if they source cotton from a listed Xinjiang producer, your finished goods are still at risk.
This is why supply chain mapping matters. You need visibility beyond tier-1 suppliers.
The Entity List Keeps Growing
DHS continues adding entities based on:
- Ongoing investigations
- New evidence from NGOs and journalists
- Congressional pressure
- Changes in Xinjiang policies
A supplier that’s clean today might be listed tomorrow. Continuous monitoring is essential.
Practical Steps for Importers
1. Screen Before Ordering
Check all new suppliers against the Entity List before placing orders.
2. Map Your Supply Chain
Know where your suppliers source their materials. Ask specifically about Xinjiang connections.
3. Get It in Writing
Require suppliers to sign declarations confirming they don’t source from Entity List companies.
4. Monitor for Updates
Set up alerts for Entity List changes. When a new entity is added, check your supply chain.
5. Document Everything
Keep screening records. If CBP ever questions your supply chain, you’ll have evidence of due diligence.
FAQs About the UFLPA Entity List
How often is the Entity List updated?
There’s no fixed schedule. DHS adds entities as investigations conclude—roughly quarterly, but sometimes more frequently.
Can companies be removed from the Entity List?
Yes, through a petition process. But it’s rare and requires substantial evidence of changed practices.
What if my supplier’s parent company is listed?
Subsidiaries and affiliates of listed entities face the same scrutiny. The connection doesn’t need to be direct.
Does the Entity List only apply to goods from China?
The list focuses on Xinjiang, but goods processed in third countries (Vietnam, Bangladesh, etc.) can still be flagged if raw materials originated from listed entities.
How do I prove my supplier isn’t connected to the Entity List?
Documentation: supplier declarations, origin certificates, supply chain maps, and ideally third-party audits.
What’s the difference between the UFLPA Entity List and OFAC sanctions?
The UFLPA Entity List is specific to forced labor. OFAC sanctions (SDN List) cover broader national security and foreign policy concerns. Smart importers screen against both.
Do I need to screen every shipment?
Screen every new supplier. For existing suppliers, re-screen when the Entity List updates or when you hear about changes in their supply chain.
The Bottom Line on the UFLPA Entity List
The Entity List isn’t going away. If anything, it will keep expanding as enforcement intensifies.
Importers who screen proactively, document their supply chains, and monitor for changes will thrive.
Those who ignore the list will face detentions, delays, and potentially devastating losses.
The choice is yours.
The UFLPA Entity List is central to every import decision you make—knowing it inside and out is no longer optional.