DHS Adds 43 Companies to UFLPA Entity List in Largest-Ever Single Expansion — Effective August 3

Key Points

• On August 3, 2026, DHS expanded the UFLPA Entity List by 43 companies — a 30% increase and the largest single addition since the law’s enactment — bringing the total to 187 listed entities.
• Effective August 3, CBP will apply the UFLPA’s rebuttable presumption to goods from (including those incorporating inputs from) any newly listed entity, requiring importers in such cases to demonstrate by clear and convincing evidence that their supply chains are free of forced labor.
• The newly listed companies span five high-priority enforcement sectors: aluminum, apparel, copper, cotton, and tomatoes.
• The DOJ/DHS Trade Fraud Task Force (TFTF) surpassed $1 billion in recoveries and charged losses in under one year, and DHS has warned that importers knowingly circumventing UFLPA restrictions can face criminal prosecution.

On July 31, 2026, the Department of Homeland Security (DHS) announced the addition of 43 companies to the Entity List under the Uyghur Forced Labor Prevention Act (UFLPA), effective August 3, 2026. DHS also announced technical name updates to two entities already on the list.

With these additions, the Entity List now covers 187 entities — a 30% increase from the prior count, making this the single largest expansion of the List since the UFLPA’s enactment.  The aggressive targeting of Chinese companies under the UFLPA by this administration stands in marked contrast with the recent criticism that the administration has not been active in its designations on the Commerce Department’s Entity List under the Export Administration Regulations (EAR).  

The 43 newly listed companies operate in sectors designated as high priority for UFLPA enforcement:

• Aluminum.
• Apparel.
• Copper.
• Cotton.
• Tomatoes and downstream tomato products.

Since the UFLPA’s implementation, CBP has denied entry to more than 24,300 shipments valued at nearly $1 billion under the statute’s authority.

Background

The UFLPA, enacted in December 2021, establishes a rebuttable presumption that goods mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region (XUAR) of China — or by entities identified on the UFLPA Entity List — are produced with forced labor and therefore prohibited from entry into the United States under 19 U.S.C. § 1307.

The UFLPA Entity List identifies entities that: (i) use forced labor or source materials from the XUAR; or (ii) work with the government of Xinjiang to recruit, transport, transfer, harbor, or receive Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the region. U.S. Customs and Border Protection (CBP) enforces the rebuttable presumption at the border. To obtain release of detained goods, an importer must either show the UFLPA is not applicable or else overcome that presumption by clear and convincing evidence — a demanding standard that, in practice, results in low approval rates for rebuttal submissions.

The Forced Labor Enforcement Task Force (FLETF), chaired by DHS and composed of representatives from Office of the U.S. Trade Representative and the Departments of Labor, State, Treasury, Justice, and Commerce, administers the Entity List.

What This Means For Importers

1. Immediate Shipment Risk. As of August 3, 2026, CBP will apply the rebuttable presumption to any goods with any of the 43 newly listed entities in their supply chains. Shipments from — or incorporating inputs from — these entities are presumed inadmissible. Importers with pending shipments, open purchase orders, or existing supplier relationships (even indirect, sub-tier) connected to any newly listed entity should assess their exposure immediately.
2. Broad Sectoral Reach. The listing of companies across varied sectors (including aluminum, copper, apparel, cotton, and tomatoes) signals continued aggressive FLETF targeting.
3. Heightened Enforcement Climate. DHS and DOJ jointly lead the Trade Fraud Task Force, which recently surpassed $1 billion in penalties, recoveries, and charged losses. DHS officials have stated that importers that knowingly circumvent UFLPA restrictions will be prosecuted “to the fullest extent of the law,” highlighting the increasing risk of criminal charges in this space.  
4. Continued List Expansion Is Expected. DHS described this announcement as the largest-ever single expansion of the Entity List, signaling that FLETF enforcement is accelerating. The 2025 Updates to the UFLPA Strategy (published August 19, 2025) articulated a continued commitment to broadening the List and designated additional high-priority sectors including steel, lithium, and caustic soda.

Recommended Actions

• Audit current direct and indirect supplier lists against the updated UFLPA Entity List.
• Review open purchase orders and in-transit shipments for any connection—direct or indirect—to newly listed entities.
• Enhance supplier due diligence protocols to include representations, warranties, and audit rights regarding XUAR or Entity List sourcing and UFLPA compliance.
• Consult trade counsel before attempting to submit a rebuttal to CBP; the evidentiary burden is significant, and submissions that fall short can delay clearance further or result in exclusion of the goods or other adverse consequences.
• Monitor the Entity List on a recurring basis; further additions are expected as the FLETF continues to expand its enforcement focus.

For guidance on UFLPA compliance, supply chain due diligence, and CBP enforcement matters, contact a member of Troutman Pepper Locke’s Sanctions + Trade Controls team or our Tariff + Trade Task Force.