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On July 9, 2024, the Department of Homeland Security (DHS), as chair of the Forced Labor Enforcement Task Force (FLETF), released an updated Uyghur Forced Labor Prevention Act (UFLPA) Strategy. This update aims to combat forced labor in U.S. supply chains by identifying new high priority sectors for enforcement: aluminum, polyvinyl chloride (PVC), and seafood. These additions reflect the Administration’s commitment to eradicating forced labor and supporting responsible businesses that uphold human rights and fair competition.
We recently published an article titled "Navigating the UFLPA: Ensuring Responsible Business Conduct in Supply Chains," which highlighted the importance of proactive supply chain audits and maintaining traceability to comply with UFLPA and other regulations. This update builds on that foundation, providing further guidance and expanding enforcement priorities.
For the first time since 2022, the FLETF has expanded its list of high priority sectors, which now includes aluminum, PVC, and seafood. These sectors were identified due to the higher risk of forced labor or state labor transfer of Uyghurs and other ethnic minorities from the Xinjiang Uyghur Autonomous Region (XUAR). This move supports ongoing efforts to monitor and regulate other high-risk sectors, such as apparel, cotton, polysilicon, and tomatoes.
The updated UFLPA Strategy builds on significant progress made since its initial release in June 2022. Key initiatives include:
Strong Enforcement by U.S. Customs and Border Protection (CBP): Enhanced scrutiny and enforcement actions at ports to prevent the importation of goods produced with forced labor.
Expansion of the UFLPA Entity List: Three new entities were added, bringing the total to 68 PRC-based companies whose goods are restricted from entering the United States.
Greater Collaboration with Stakeholders: Engagement with stakeholders, including industry leaders, civil society, and international partners, to support compliance and eradicate forced labor.
The designation of new high priority sectors means that entities within these sectors will be subject to rigorous review and potential enforcement actions, such as inclusion on the UFLPA Entity List, export limitations, economic sanctions, and visa restrictions. These measures aim to deter participation in or facilitation of forced labor, ensuring that U.S. markets remain free of goods produced under such conditions.
Robert Silvers, Under Secretary for Policy and Chair of the FLETF, emphasized the Administration’s dedication to expanding enforcement and protecting workers’ rights. Troy A. Miller, CBP Senior Official Performing the Duties of the Commissioner, highlighted the significant impact of these efforts, noting that nearly 3,500 shipments valued at over $695 million have been denied entry.
The updated UFLPA Strategy represents a comprehensive approach to tackling forced labor in global supply chains. By identifying new high priority sectors and enhancing enforcement actions, the DHS and FLETF are taking critical steps to protect human rights, support fair competition, and uphold labor standards. Businesses are encouraged to strengthen their due diligence to ensure compliance and contribute to the global fight against forced labor.
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