The Complete UFLPA Entity List as of 2024 (October)

UPDATE: Three new entities have been added to the UFLPA Entity List as of October 3, 2024. See their names below on the full list. 

Enacted on December 23, 2021, the Uyghur Forced Labor Prevention Act (UFLPA) was passed with the goal of preventing U.S. importers from doing business with any companies implicated in forced labor practices in the Xinjiang-Uyghur Autonomous Region (XUAR) in China. The law, which went into effect in June of the following year, carries out this prohibition on goods imported from the XUAR in two ways.

First, it establishes a “rebuttable presumption” that any commodities manufactured in whole or part in the XUAR were done so using forced labor, and are thus subject to 19 U.S. Code § 1307, which prohibits the importation of any products manufactured through such means. Importers may request an exception to this sweeping presumption from Customs and Border Protection, the federal agency responsible for the law’s implementation and enforcement. Businesses must clear a high bar, however, to attain those exemptions, including by showing full compliance with the UFLPA’s due diligence requirements and by providing “clear and convincing” evidence that the goods in question were not produced using forced labor.

CBP’s second means of enforcement is through the UFLPA Entity List. Initially published by the Department of Homeland Security on June 21, 2022, this list consists of organizations that are based in Xinjiang and mine, produce, or manufacture goods using forced labor, and those that collaborate with the Chinese government to recruit, transport, or receive Uyghurs and other persecuted groups from Xinjiang for the purposes of forced labor. In addition, the list also encompasses entities known to be participating in the country’s “poverty alleviation” and “pairing assistance” programs—government schemes widely understood to be thinly-veiled guises for systematic forced labor.  

CBP maintains statistics on the UFLPA, and recent figures demonstrate that the agency’s enforcement has grown increasingly robust since the law’s enactment in 2022. In fiscal year 2023, CBP detained a total of $1.42 billion worth of shipments for UFLPA compliance review. The agency reached that figure through the first seven months of fiscal year 2024, increasing the frequency of detainments in categories such as electronics, apparel, and industrial materials. While the number of denied shipments ticked downward over the summer, 2024 will still easily surpass each of the previous two years in terms of the total value of detainments, and may come close to approaching $2 billion. Meanwhile, this past March continues to represent the peak of UFLPA enforcement, with CBP detaining $300 million of imported goods and subjecting them to the agency’s review process. 

Since the law went into effect over two years ago, dozens of companies—including many that allegedly operated under various aliases—have been added to the DHS’s UFLPA Entity List. While these firms work in a wide range of industries that include non-ferrous metals, printing and imaging, and hair products, the list puts an especially strong emphasis on textile manufacturing businesses (CBP statistics indicate that UFLPA shipment interdictions are also heavily focused on electronics). This may be a function of the predominant sectors in the XUAR, the specific industries being targeted by the Chinese Communist Party’s (CCP) forced labor programs, or the risk assessments and intelligence-gathering efforts of the Forced Labor Enforcement Task Force (FLETF), the interagency group charged with enforcing 19 U.S. Code § 1307.

Companies Added to UFLPA Entity List on June 21, 2022

1. Baoding LYSZD Trade and Business Co., Ltd. 
2. Changji Esquel Textile Co. Ltd. (and one alias : Changji Yida Textile)
3. Hetian Haolin Hair Accessories Co. Ltd. (and two aliases: Hotan Haolin Hair Accessories; and Hollin Hair Accessories)
4. Hetian Taida Apparel Co., Ltd (and one alias: Hetian TEDA Garment)
5. Hoshine Silicon Industry (Shanshan) Co., Ltd (including one alias: Hesheng Silicon Industry (Shanshan) Co.) and subsidiaries
6. Xinjiang Daqo New Energy, Co. Ltd (including three aliases: Xinjiang Great New Energy Co., Ltd.; Xinjiang Daxin Energy Co., Ltd.; and Xinjiang Daqin Energy Co., Ltd.)
7. Xinjiang East Hope Nonferrous Metals Co. Ltd. (including one alias: Xinjiang Nonferrous)
8. Xinjiang GCL New Energy Material Technology, Co. Ltd (including one alias: Xinjiang GCL New Energy Materials Technology Co.)
9. Xinjiang Junggar Cotton and Linen Co., Ltd.
10. Xinjiang Production and Construction Corps (including three aliases: XPCC; Xinjiang Corps; and Bingtuan) and its subordinate and affiliated entities
11. Aksu Huafu Textiles Co. (including two aliases: Akesu Huafu and Aksu Huafu Dyed Melange Yarn)
12. Hefei Bitland Information Technology Co., Ltd. (including three aliases: Anhui Hefei Baolongda Information Technology; Hefei Baolongda Information Technology Co., Ltd.; and Hefei Bitland Optoelectronic Technology Co., Ltd.)
13. Hefei Meiling Co. Ltd. (including one alias: Hefei Meiling Group Holdings Limited)
14. KTK Group (including three aliases: Jiangsu Jinchuang Group; Jiangsu Jinchuang Holding Group; and KTK Holding)
15. Lop County Hair Product Industrial Park
16. Lop County Meixin Hair Products Co., Ltd.
17. Nanjing Synergy Textiles Co., Ltd. (including two aliases: Nanjing Xinyi Cotton Textile Printing and Dyeing; and Nanjing Xinyi Cotton Textile)
18. No. 4 Vocation Skills Education Training Center (VSETC)
19. Tanyuan Technology Co. Ltd. (including five aliases: Carbon Yuan Technology; Changzhou Carbon Yuan Technology Development; Carbon Element Technology; Jiangsu Carbon Element Technology; and Tanyuan Technology Development)
20. Xinjiang Production and Construction Corps (XPCC) and its subordinate and affiliated entities
21. Yili Zhuowan Garment Manufacturing Co., Ltd.

Companies Added to UFLPA Entity List in 2023

1. Ninestar Corporation and its eight Zhuhai-based subsidiaries, which include Zhuhai Ninestar Information Technology Co. Ltd., Zhuhai Pantum Electronics Co. Ltd., Zhuhai Apex Microelectronics Co., Ltd., Geehy Semiconductor Co., Ltd., Zhuhai Pu-Tech Industrial Co., Ltd., Zhuhai G&G Digital Technology Co., Ltd., Zhuhai Seine Printing Technology Co., Ltd., and Zhuhai Ninestar Management Co., Ltd.
2. Xinjiang Zhongtai Chemical Co. Ltd.
3. Camel Group Co., Ltd.
4. Xinjiang Tianmian Foundation Textile Co., Ltd.
5. Xinjiang Tianshan Wool Textile Co. Ltd.
6. Xinjiang Zhongtai Group Co. Ltd
7. Chenguang Biotech Group Co., Ltd. and its subsidiary Chenguang Biotechnology Group Yanqi Co. Ltd.
8. Anhui Xinya New Materials Co., Ltd. (formerly known as Chaohu Youngor Color Spinning Technology Co., Ltd.; and Chaohu Xinya Color Spinning Technology Co., Ltd.)
9. COFCO Sugar Holdings Co., Ltd.
10. Sichuan Jingweida Technology Group Co., Ltd. (also known as Sichuan Mianyang Jingweida Technology Co., Ltd. and JWD Technology; and formerly known as Mianyang High-tech Zone Jingweida Technology Co., Ltd.)

The final three companies—Xinya New Materials, COFCO Sugar, and Jingweida Technology—were added by the DHS in December 2023. Xinya New Materials, a textile manufacturer based in Anhui Province, was found to be collaborating with a known forced-labor program, Xinjiang Aid, to recruit individuals living in Xinjiang and transfer them to Anhui Province to work at its facilities. COFCO Sugar, a sugar and vegetable processing company headquartered in Xinjiang, participated in a PRC poverty alleviation program and traveled to XUAR villages to recruit members of persecuted ethnic minorities to work at the firm’s facilities. And Jingweida Technology, an electronics manufacturer that produces network transformers and other magnetic devices, cooperated with the local government in Awati County to transfer members of persecuted groups out of Xinjiang to work in its factories in Sichuan Province. 

Companies Added to UFLPA Entity List in 2024

1. Binzhou Chinatex Yintai Industrial Co., Ltd.
2. China Cotton Group Henan Logistics Park Co., Ltd., Xinye Branch
3. China Cotton Group Nangong Hongtai Cotton Co., Ltd.
4. China Cotton Group Shandong Logistics Park Co., Ltd.
5. China Cotton Group Xinjiang Cotton Co.
6. Fujian Minlong Warehousing Co., Ltd.
7. Henan Yumian Group Industrial Co., Ltd.
8. Henan Yumian Logistics Co., Ltd. (formerly known as 841 Cotton Transfer Warehouse)
9. Hengshui Cotton and Linen Corporation Reserve Library
10. Heze Cotton and Linen Co., Ltd.
11. Heze Cotton and Linen Economic and Trade Development Corporation (also known as Heze Cotton and Linen Trading Development General Company)
12. Huangmei Xiaochi Yinfeng Cotton (formerly known as Hubei Provincial Cotton Corporation's Xiaochi Transfer Reserve)
13. Hubei Jingtian Cotton Industry Group Co., Ltd.
14. Hubei Qirun Investment Development Co., Ltd.
15. Hubei Yinfeng Cotton Co., Ltd.
16. Hubei Yinfeng Warehousing and Logistics Co., Ltd.
17. Jiangsu Yinhai Nongjiale Storage Co., Ltd.
18. Jiangsu Yinlong Warehousing and Logistics Co., Ltd.
19. Jiangyin Lianyun Co. Ltd. (also known as Jiangyin Intermodal Transport Co. and Jiangyin United Transport Co.)
20. Jiangyin Xiefeng Cotton and Linen Co., Ltd.
21. Juye Cotton and Linen Station of the Heze Cotton and Linen Corporation
22. Lanxi Huachu Logistics Co., Ltd.
23. Linxi County Fangpei Cotton Buying and Selling Co., Ltd.
24. Nanyang Hongmian Logistics Co., Ltd. (also known as Nanyang Red Cotton Logistics Co., Ltd.)
25. Wugang Zhongchang Logistics Co., Ltd.
26. Xinjiang Yinlong Agricultural International Cooperation Co.
27. Dongguan Oasis Shoes Co., Ltd. (also known as Dongguan Oasis Shoe Industry Co. Ltd.; Dongguan Luzhou Shoes Co., Ltd.; and Dongguan Lvzhou Shoes Co., Ltd.)
28. Shandong Meijia Group Co., Ltd. (also known as Rizhao Meijia Group)
29. Xinjiang Shenhuo Coal and Electricity Co., Ltd.
30. Kashgar Construction Engineering (Group) Co., Ltd.
31. Xinjiang Habahe Ashele Copper Co., Ltd. (also known as Ashele Copper)
32. Xinjiang Tengxiang Magnesium Products Co., Ltd.
33. Century Sunshine Group Holdings, Ltd.
34. Rare Earth Magnesium Technology Group Holdings, Ltd.
35. Baowu Group Xinjiang Bayi Iron and Steel Co., Ltd. (also known as Xinjiang Bayi Iron and Steel Co. Ltd.; Baosteel Group Xinjiang Bayi Iron and Steel Co., Ltd.; and Bayi Iron and Steel)
36. Changhong Meiling Co., Ltd. (formerly known as Hefei Meiling Co., Ltd.; and Hefei Meiling Group Holdings Limited)
37. Changzhou Guanghui Food Ingredients Co., Ltd. (also known as GSweet; Changzhou Guanghui Food Additive Co., Ltd.; and Changzhou Guanghui Food Technology Co., Ltd.; and formerly known as Changzhou Guanghui Biotechnology Co., Ltd.)

Newly Listed Entity Has Ties to Zijin Mining Group Co., Ltd.

Xinjiang Habahe Ashele Copper Co., Ltd. (also known as Ashele Copper) is a subsidiary of Zijin Mining Group Co., Ltd, a multinational mining group found in the supply chain of a number of major companies, especially as a supplier of gold. Zijin is in a number of supply chains in the semiconductor, IP&E, automotive, electrical solutions industry, and more. 

 Want to see your potential ties to these newly banned entities in your subtier? Contact Z2Data for a free consultation. 

Supply Chains Respond to the UFLPA Crackdown 

As CBP’s UFLPA dashboard demonstrates, the level and scope of the law’s enforcement was steadily increasing in 2024 before a notable slide in the second and third quarters of the year. There are a few possible factors that could be contributing to this trend. First, the number of solar panel shipments detained by CBP has declined significantly since its peak earlier in the year. Once accounting for nearly half of all detentions, during the month of June only around a quarter of the total value of CBP detainments came from such shipments. 

Second, and more encouragingly, there are signs that U.S. importers and manufacturers may be reconfiguring their supply chains as a direct consequence of the rise of the UFLPA. Speaking to the Center for Strategic & International Studies (CSIS) in June, Department of Homeland Security Secretary Alejandro Mayorkas observed that the DHS has seen companies “begin to shift their supply chains in very, very significant ways.” In the solar industry in particular, Mayorkas remarked that he and his team at DHS have seen firms begin to transition away from Xinjiang province—which produces a substantial portion of the world’s polysilicon—to other sourcing partners. “We’ve seen them shift the supply chain to a point where, by 2026, I believe, we’re going to see a 200 percent increase in the manufacture of solar-trade polysilicon in North America and India,” he said. 

These signs of substantive changes in sourcing and supply chains that were once enmeshed, wittingly or otherwise, in forced labor practices testify to the persuasive power of the UFLPA and two years of robust enforcement. These shifting sourcing patterns have also come on the heels of a sustained and vigorous push to strengthen the law. Over the course of 2023, multiple congressional groups, including the bill’s original sponsors and the House Select Committee on the CCP, submitted policy recommendations aimed at expanding the UFLPA and its enforcement mechanisms. Social justice and human rights organizations, meanwhile, continued agitating for more aggressive measures to punish China’s inhumane practices and interdict goods implicated in the CCP’s forced-labor programs from entering the U.S. supply chains. 

It seems that these concerted, yearslong efforts to impose accountability on the CCP and reduce the suffering of Uyghurs and other ethnic minorities in the XUAR are finally starting to pay off. Nevertheless, much work remains to be done. Forced labor experts have suggested that as many as 55,000 companies are operating in some capacity in the Uyghur Region, with at least 150 knowingly participating in state-sponsored labor transfer programs. So while the number of CBP detainments might have decreased in recent months, the moral imperative for the law to continue pressuring companies to restructure their supply chains away from Xinjiang is as strong as ever.