# UFLPA traceability: supply chain evidence for US importers > How the Uyghur Forced Labor Prevention Act works, the high-priority sectors, the July 2026 Entity List expansion and the traceability file US importers need. Source: https://sourcesquid.co/compliance/uflpa/ US · Customs · Public Law 117-78 # UFLPA: traceability down to the raw material. The Uyghur Forced Labor Prevention Act presumes that goods made wholly or partly in Xinjiang, or by entities on the UFLPA Entity List, are made with forced labour, and US Customs and Border Protection has enforced that presumption since 21 June 2022. US importers keep goods moving with traceability to raw-material origin: documents showing where every input came from, down to the cotton, polysilicon, aluminium or PVC. [Get my UFLPA risk map](https://sourcesquid.co/start/?from=compliance-uflpa) See the key dates 21 Jun 2022 presumption enforced by CBP 5 priority sectors added in Aug 2025 43 entities added on 31 Jul 2026 Status · checked 28 Sep 2026 **Enforced since 21 Jun 2022** 1. 23 Dec 2021UFLPA enacted 2. 21 Jun 2022Rebuttable presumption enforced 3. 19 Aug 2025Strategy update: five new priority sectors 4. 31 Jul 202643 companies added to the Entity List 5. Today28 Sep 2026 All dates and references ↓ The short answer ## What you need to know. Checked against official sources on 28 September 2026. 1. 01 The UFLPA (Public Law 117-78) was enacted on **23 December 2021**. Since **21 June 2022** , CBP applies a **rebuttable presumption** that goods made wholly or in part in Xinjiang, or by listed entities, are made with forced labour and may not enter the US. 2. 02 The presumption reaches **every input**. A product assembled in India, Vietnam or China is detained if its cotton, yarn, polysilicon, aluminium or PVC traces back to Xinjiang or a listed entity. 3. 03 To obtain an exception, the importer must follow the UFLPA guidance, answer CBP’s requests **completely and substantively** , and show by **clear and convincing evidence** that no forced labour was involved (Sec. 3(b)). 4. 04 High-priority sectors include apparel, cotton, polysilicon, tomatoes, aluminium, PVC and seafood; the **August 2025** update added caustic soda, jujubes, copper, lithium and **steel**. 5. 05 The Entity List keeps growing: on **31 July 2026** DHS added 43 companies. Re-screen suppliers and their input suppliers after each update. Who it applies to ## If it enters the US, its inputs are in scope. Importer of record ### US importers and brands Carry the burden of proof when CBP detains a shipment. They need the traceability file ready before goods ship. Factories in China ### Direct suppliers Must show that no inputs come from Xinjiang or listed entities, including through their own suppliers. Factories elsewhere ### India, Vietnam and beyond In scope through their inputs: Chinese yarn, fabric, aluminium extrusions, PVC compounds or polysilicon. Input suppliers ### Mills, spinners, smelters Hold the records that close the chain: purchase and production records for raw materials. Key dates ## Every date, with its source. UFLPA is already fully in force. These are the milestones that changed what importers need to check. 1. 23 Dec 2021 ### UFLPA enacted Public Law 117-78 signed into law. Public Law 117-78Enacted 2. 21 Jun 2022 ### Rebuttable presumption enforced CBP begins applying the presumption to goods linked to Xinjiang or listed entities. UFLPA Sec. 3In force 3. 19 Aug 2025 ### Strategy update: five new priority sectors Caustic soda, jujubes (red dates), copper, lithium and steel added to the high-priority sectors. UFLPA Strategy, 2025 updatePublished 4. 31 Jul 2026 ### 43 companies added to the Entity List The largest single expansion so far, according to commentators, with many entities in aluminium, apparel, cotton and tomatoes. UFLPA Entity ListPublished 5. Today · 28 September 2026 Example trace ## One T-shirt, five tiers of evidence. Example: a cotton T-shirt sewn in Vietnam for a US brand. The presumption looks through every tier, so the file does too. 1. Tier 0**US importer** _Entry documents, commercial invoice_ 2. Tier 1**Garment factory, Vietnam** _Production records, fabric receipts_ 3. Tier 2**Fabric mill** _Yarn purchase orders and lot records_ 4. Tier 3**Spinning mill** _Cotton bale purchases, invoices, payments_ 5. Tier 4**Cotton origin** _Origin records for each bale lot_ Example, shown to illustrate the method. Real chains often branch: trims, thread and packaging have their own tiers. What you need from suppliers ## A traceability file that answers CBP. Documents that connect each shipment to its raw material, and that reconcile with each other on quantities and dates. * **Supply chain map for each product** Every tier from the finished-goods factory to the raw material, with names and addresses. * **Purchase orders and invoices at each tier** Linking the quantities bought to the quantities used in your order. * **Production records** Batch or lot records showing which inputs went into which production run. * **Transport documents for inputs** Bills of lading, packing lists and delivery notes that confirm where inputs came from. * **Proof of payment** Payments that match the invoices at each tier of the chain. * **Raw-material origin evidence** Origin records for cotton bales, mill certificates for steel and aluminium, and similar evidence per input. How SourceSquid helps ## From your product list to an audit-ready file. Our teams in Bengaluru and Ningbo collect the evidence at the factory, in the supplier’s own language, while production runs. 1. 01 ### Risk screen Your products checked against the high-priority sectors and the inputs most likely to trace to Xinjiang. You receiveUFLPA risk map 2. 02 ### Entity screening Suppliers and their input suppliers screened against the UFLPA Entity List, and re-screened after every update. You receiveScreening record 3. 03 ### Tier-n mapping Our teams in Ningbo and Bengaluru trace each chain to spinner, smelter or compounder, on site where needed. You receiveTraceability map 4. 04 ### Document collection Purchase, production, transport and payment records gathered at each tier and checked so quantities reconcile. You receiveReconciled document set 5. 05 ### Alternative inputs Where a chain cannot be proven, we source inputs with clear origin, often in India. You receiveQualified alternative supplier 6. 06 ### Detention-ready file One organised file per product, ready for your customs broker if CBP asks. You receiveAudit-ready traceability file Sources ## Official texts behind this page Checked on 28 September 2026. This page explains the rules in plain English; for a view on your own products, ask our team or your legal adviser. 1. [US Customs and Border Protection: Uyghur Forced Labor Prevention Act](https://www.cbp.gov/trade/forced-labor/UFLPA)Rebuttable presumption; exceptions; applicability reviews 2. [US Department of Homeland Security: UFLPA Strategy](https://www.dhs.gov/uflpa-strategy) 3. [US Department of Homeland Security: UFLPA Entity List](https://www.dhs.gov/uflpa-entity-list) 4. [US Department of Labor: 2025 UFLPA Strategy update (19 Aug 2025)](https://www.dol.gov/newsroom/releases/ilab/ilab20250819)Five new high-priority sectors 5. [Thompson Hine: UFLPA annual strategy update (commentary)](https://www.thompsonhine.com/insights/uflpa-annual-strategy-update-u-s-department-of-homeland-security-designates-new-high-priority-sectors-and-adds-78-entities-to-forced-labor-list/)Sectors designated 2022–2025 6. [Covington: DHS expands UFLPA Entity List (commentary, Aug 2026)](https://www.cov.com/en/news-and-insights/insights/2026/08/dhs-expands-uflpa-entity-list-amid-intensifying-enforcement-landscape)43 entities added on 31 July 2026 Related compliance guides ## Rules that often travel together. [EU · deforestation**EUDR** Deforestation Regulation: due diligence statements and plot geolocation for seven commodities.](https://sourcesquid.co/compliance/eudr/)[EU · carbon**CBAM** Carbon Border Adjustment Mechanism: embedded emissions and certificates for steel, aluminium and more.](https://sourcesquid.co/compliance/cbam/)[Weekly updates**Compliance Radar** Recent and upcoming rule changes, dated and sourced.](https://sourcesquid.co/compliance/radar/) UFLPA questions ## Straight answers. Dates checked against official sources. We update this page when the rules move. [anirudh@sourcesquid.co](mailto:anirudh@sourcesquid.co) ### What is the UFLPA rebuttable presumption? Since 21 June 2022, US Customs and Border Protection presumes that goods mined, produced or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or by an entity on the UFLPA Entity List, are made with forced labour and are barred from import into the United States. The presumption applies to every input, not just the finished product. ### How can an importer overcome the UFLPA presumption? Under Section 3(b) of the Act, CBP may grant an exception only if the importer has fully complied with the UFLPA guidance, has completely and substantively responded to all CBP requests for information, and shows by clear and convincing evidence that the goods were not made wholly or in part with forced labour. Separately, an importer can show the goods have no connection to Xinjiang or listed entities through an applicability review. ### Which sectors are high priority for UFLPA enforcement? Sectors named in the UFLPA Strategy before 2025 are apparel; cotton and cotton products; silica-based products including polysilicon; tomatoes and downstream products; aluminium; PVC; and seafood. The 19 August 2025 update added caustic soda, jujubes (red dates), copper, lithium and steel. ### Does UFLPA affect products made in India or Vietnam? Yes, if any input traces back to Xinjiang or to a listed entity. A garment sewn in Vietnam or India from yarn or cotton sourced from Xinjiang is covered by the presumption. That is why traceability has to reach the raw material, not just the final factory. ### How often does the UFLPA Entity List change? It is updated from time to time by the Forced Labor Enforcement Task Force. On 31 July 2026, DHS added 43 companies, described by commentators as the largest single expansion so far, with many in aluminium, apparel, cotton and tomatoes. Screen suppliers and their input suppliers after every update. Start here ## Every input traced. Every shipment ready. Send us the products you import into the US. We return a UFLPA risk map and the traceability plan for each supply chain. [Get my UFLPA risk map](https://sourcesquid.co/start/?from=compliance-uflpa)[Talk to a principal](https://sourcesquid.co/contact/)