What is the UFLPA Entity List? The Xinjiang presumption and what it means for clothing imports

The UFLPA Entity List is the Department of Homeland Security's public list of companies tied to forced labor in Xinjiang, and it sits at the center of a U.S. import rule that matters to every clothing brand sourcing abroad. Under the Uyghur Forced Labor Prevention Act, Public Law 117-78, goods made wholly or in part in Xinjiang are presumed to be made with forced labor and barred from entry. The importer, not the government, has to prove otherwise.

The rule in the statute

The core is section 3. It says Customs and Border Protection applies a presumption, with exceptions, to goods "mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region." The presumption also reaches goods produced by entities on the lists described in section 2(d)(2)(B). Under it, the goods are treated as prohibited under section 307 of the Tariff Act of 1930 and are not entitled to entry at U.S. ports.

CBP's own page gives the start date: "The rebuttable presumption goes into effect on June 21, 2022." Section 3(e) of the law ties the effective date to 180 days after enactment. CBP also describes its role directly: "CBP leads the implementation of the rebuttable presumption under the UFLPA."

Notice the wording "wholly or in part." A shirt assembled in a third country can be caught if a component, such as the fabric or the yarn, came from the region. That is why the rule is a supply chain problem, not a country-of-origin label problem. Our explainer on clothing country of origin rules covers the label side, which is a different test.

What the importer has to show

Section 3(b) sets the exception. The presumption does not apply if the importer of record has fully complied with the required guidance and fully responded to Customs' information requests. The importer must also show, "by clear and convincing evidence," that the goods were not made wholly or in part with forced labor. CBP's page describes the same standard, and says it conducts applicability and exception reviews when goods are detained.

That is a high bar. "Clear and convincing" is stricter than a simple balance of probabilities. In practice, it points an importer toward records: purchase orders, supplier lists, transport documents, and proof tracing inputs to their origin. The statute describes what must be shown, not which documents win, and we did not find a checklist in the sources we opened.

What the Entity List contains

The list is organized by the statute's categories. According to the DHS page, the sections cover:

• Section 2(d)(2)(B)(i): entities in Xinjiang that mine, produce or manufacture goods wholly or in part with forced labor.
• Section 2(d)(2)(B)(ii): entities that recruit, transport or move forced labor out of the region.
• Section 2(d)(2)(B)(iv): exporters of such goods into the United States. DHS says it has "not identified additional exporters at this time but will continue to investigate."
• Section 2(d)(2)(B)(v): facilities that source material under "poverty alleviation" or "pairing-assistance" programs, as described in the law.

Some companies appear in more than one section. The page does not state a total, and it does not classify entities by industry, so we do not give a count of apparel or textile names. We can say that names on the list include Kuitun Yadasi Textile Co., Ltd., which the page places under section (ii) with an August 3, 2026 effective date.

The latest update

The DHS page shows "Last Updated: 07/31/2026" and says the Forced Labor Enforcement Task Force chair announced new additions. The most recent effective date on the page is August 3, 2026. Additions that day include one company under section (i), five under section (ii), and more under section (v). Judging by their names, other companies in that update are in energy, food, pharmaceuticals and construction, which is a reminder that the law reaches far beyond clothing.

Entity List status is separate from the presumption itself. The presumption covers Xinjiang-made goods whether or not the supplier is named. Being listed adds a second route to detention.

What it means for brands and shoppers

For brands, the practical consequence is traceability. A brand importing garments has to know where the fabric, yarn and, in cotton garments, the fiber came from. Our piece on US clothing tariffs by country covers the other cost of sourcing decisions, which is duty. The two rules interact because they push the same direction: diversify and document.

For shoppers, the effect is less visible. A detained shipment never reaches a store, so a brand might simply run short of a style without saying why. We have no basis to say how often that happens in apparel. CBP publishes a dashboard with statistics on shipments subjected to UFLPA reviews and enforcement actions, and a data dictionary. Its figures are not on the page we read, and we did not open the dashboard itself, so we publish no enforcement numbers here.

What the law does not say

It does not say that all Chinese goods are barred. It does not say that cotton or apparel is the sole target; the text covers any goods from the region. And it does not declare any named brand guilty of anything. A listed supplier is a supplier on a government list, and a brand's relationship to it has to be shown by evidence, not inferred from a name.

Our take

The UFLPA turned a moral question into a documentation problem, and the burden sits on the party with the most access to the facts: the importer. For brands, a mapped supply chain is no longer a sustainability brochure item; it is how a shipment clears. For readers, the useful move is to judge a brand's claims by whether it can say where its materials come from, and to read the DHS list directly, since it changes.