The UFLPA Entity List in 2026: Screening Your Supplier Map Before Chinese New Year Orders

By Bernardo Campelo, Forbes Business Council E-Commerce Leader, Amazon SPN Certified provider, Amazon SP-API authorized partner, and Founder of PrepVia.

As of October 29, 2026, the UFLPA Entity List names 190 entities, and it got there in two steps this year. A Federal Register notice of August 3, 2026 (91 FR 48913) added 43 entities and put the list at 187. A second Federal Register notice of October 29, 2026 (91 FR 68159) added three related genomics companies and brought it to 190.

The list matters because of what the law does with it. Under the Uyghur Forced Labor Prevention Act (UFLPA), CBP presumes that goods produced by a listed entity are made with forced labor and are not entitled to entry, unless the importer of record qualifies for an exception. When DHS announced the August additions, it called them "the single largest-ever expansion of the List."

The list is where screening starts, not where it ends. The same law presumes forced labor for anything made wholly or in part in Xinjiang, whoever made it, and CBP says a Xinjiang supplier at tier 3 or tier 4 is enough to put the finished product under that presumption. With Chinese New Year 2027 on Saturday, February 6, the purchase orders that go out in November are the ones to screen now.

Every date and name below was checked on October 29, 2026 against the Federal Register, DHS, CBP, the text of the law and the Hong Kong Observatory calendar, linked where they first appear. The list changes by Federal Register notice, so check the DHS UFLPA Entity List page before you rely on the count. This is general information, not legal or customs advice: for a specific shipment, talk to your licensed customs broker or a trade attorney.

Two Updates in Three Months

Before August 2026, the list had not moved since January 15, 2025. The August notice says it "supersedes the UFLPA Entity List published in the Federal Register on January 15, 2025 (90 FR 3899)." In 2026 it changed twice, 87 days apart.

The law asks for four lists, and both 2026 rounds used two of them. The labor-transfer sub-list covers entities working with the Xinjiang government to recruit, transport, transfer, harbor or receive forced labor, or Uyghurs and members of other persecuted groups, out of Xinjiang. The sourcing sub-list covers facilities and entities that source material from Xinjiang, or from those working with its government or the Xinjiang Production and Construction Corps on labor schemes such as "poverty alleviation."

DHS said the August additions were a 30% increase in the number of listed entities, and on October 28 it called that round "the largest single expansion since the list was created." Both are DHS's words; the notices only give counts. Two details matter when you match names: DHS counts every named company, including named subsidiaries, as a separate entity, and the notice says the list "should not be interpreted as an exhaustive list" of entities engaged in the practices the law targets.

A new listing comes with no lead time. DHS says goods from a newly listed entity fall under the presumption from "the date of publication of the Federal Register Notice," and neither 2026 notice mentions a grace period for goods in transit. The three October companies sell genomic sequencing services, instruments and reagents; for most consumer brands, the October update matters for its pace.

The August Additions, Sector by Sector

Forty-one of the 43 August entities went on the sourcing sub-list, and many of them are outside Xinjiang: they were listed for buying material from it. These are the entries apparel, home and electronics brands should read first.

The rest of the round runs from tomatoes to pharmaceuticals and gold. For a finished-goods brand, the exposure tends to sit upstream, in the yarn, the foil or the copper wire a supplier buys.

DHS's UFLPA FAQ lists 12 high-priority sectors for enforcement. The law itself named only "cotton, tomatoes, and polysilicon." The first UFLPA strategy, in 2022, added apparel; DHS added aluminum, PVC and seafood in 2024, and caustic soda, copper, lithium, red dates and steel in its 2025 strategy update. The same FAQ names the products downstream:

• Aluminum. "automobiles, consumer electronics, industrial goods."
• Copper. Products from appliances and computers to medical devices, semiconductors and smart phones.
• Cotton and cotton products. "apparel, home goods (sheets, curtains, and upholstery fabrics), personal hygiene products."
• PVC. "flooring, plumbing suppliers, including pipe."

None of the 46 entities added in 2026 is described as a PVC producer. PVC stays a high-priority sector anyway: the 2024 strategy update notes that Xinjiang "produces more than 10 percent of the world’s PVC," and the two Xinjiang Zhongtai companies it names as PVC producers have been on the list since 2023. A product outside the 12 sectors is not exempt either: DHS says CBP targets goods "from all sectors" with a nexus to Xinjiang.

Why the List Is Not the Whole Screen

The presumption has two triggers, and only one of them is the list. Section 3 of the law covers goods "mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region" and goods "produced by an entity on a list." A supplier can pass a name check and still ship a product with a Xinjiang input.

The input does not have to come straight from Xinjiang either. DHS says the presumption reaches "goods produced in other parts of China or in other countries that incorporate goods that were produced in Xinjiang or by entities on the UFLPA Entity List." It also applies to goods moving in bond, through a Foreign Trade Zone or through a customs bonded warehouse.

CBP answers the tier question directly in its UFLPA enforcement FAQ. Asked whether a Xinjiang supplier at tier 3 or 4, of a component that is "a small/minor percentage of the final imported product," puts the finished product under the presumption, CBP says: "Yes. Any goods made with any inputs from XUAR are presumed to be made with forced labor under UFLPA."

The tiers are DHS's own vocabulary. Its UFLPA strategy says: "First-tier suppliers are those who supply direct to the business, second-tier are suppliers to the first-tier, and so on until the raw or near-raw supplier level." It expects the map to go "up to and including suppliers of raw materials used in the production of the imported good or material."

Subsidiaries follow the names. DHS says goods from an unnamed subsidiary or affiliate are not automatically covered, unless the parent's listing carries the words "subsidiaries" or "affiliated entities," but they "may undergo examination" all the same.

Do not confuse the UFLPA with the 2026 Section 301 forced labor duty: they do different things. The UFLPA decides whether goods may enter at all. The Section 301 action of July 28, 2026 (91 FR 47318) is an added duty, from July 24, 2026, on products of the economies USTR investigated for failing to impose and effectively enforce a ban on goods made with forced labor; our 2026 tariff stack covers it.

Screening the Supplier Map Before the CNY Purchase Orders

Our Chinese New Year 2027 inventory plan covers the production calendar. This is the compliance side of the same purchase orders.

• Start with tier 1 and tier 2. List every factory you buy from and the suppliers of its main materials and components. Match each name against the DHS list, including every "also known as" and "formerly known as" entry and the subsidiaries named under a parent.
• Match more than one spelling. DHS provides the English-language names of listed entities, and names change: in August 2026 it renamed two existing entries, one to Xinjiang Goens Energy Technology and one to Kuitun Yadasi Textile.
• Go past tier 2, high-priority sectors first. For cotton, aluminum, copper and PVC, trace to the raw material: the cotton bale, the smelter, the ethylene and chlorine. Every other product needs the same map in the end: CBP's tier 3 and tier 4 answer covers any input from Xinjiang, and a detention review needs records from every supplier in the chain.
• Ask for records before the order. CBP's advice is to "Prepare a plan for responding to a detention under the UFLPA," including confirming that suppliers know the law and keeping documentation "for ready/immediate submission to CBP." A supplier protecting its own information can send records to CBP directly, as long as the importer is told.
• Watch for mixed sourcing. DHS warns that inputs from factories sourcing both inside and outside Xinjiang put shipments at risk of detention, because it may be harder to show the materials were not mixed.
• Check again at every update. A listing applies from the day its notice is published, and the list moved twice in 2026.

CBP's own worked example follows the same order. In its 2026 importer guidance, a small apparel importer first checks the UFLPA Entity List and CBP's Withhold Release Orders and Findings dashboard, then requests transaction, payment and shipping records from every company in the chain, down to where the cotton was sourced. For a supplier that "cannot or will not provide the documentation requested," CBP's advice is to "consider finding a new supplier." November is a better time for that decision than February.

"The Entity List is where screening starts, not where it ends. It changed in August and again in October, and the law also reaches Xinjiang inputs from companies that are not on it."

Bernardo Campelo, Founder of PrepVia

CBP is also asking how much of this map it should see at entry. An advance notice published September 2, 2026 (91 FR 56408) asks whether CBP should collect information to identify "the manufacturer, shipper, and exporter for each shipment," with comments due December 1, 2026. It is a request for comments, not a rule; our seller calendar for 2027 tracks the date.

When CBP Detains a Shipment: The Clock

CBP's current playbook is its Forced Labor Enforcement Operational Guidance for Importers, published June 12, 2026, which replaced the June 2022 UFLPA guidance. When CBP has information that a shipment may contain an input from Xinjiang or a listed entity, a "potential input," it may detain the goods or, depending on how certain the link is, exclude them. When the information indicates it does, a "direct input," the goods are excluded.

A detention comes as a notice on CBP Form 6051D, with an Attachment 2-B that lists example documents. The importer has 30 days to respond: export or destroy the goods, or request a review. While a review runs, the importer pays the storage, and CBP may require a single-transaction bond of three times the value of the detained goods.

The review comes in two kinds, and they ask for different things. After a detention notice, both are requested through CBP's Forced Labor Portal; after an exclusion, they go in as a protest in ACE.

• Applicability review. The importer argues the UFLPA does not apply because no goods or inputs came from Xinjiang or a listed entity. The assigned CBP Center of Excellence and Expertise handles it, and DHS says the clear-and-convincing standard does not apply to this showing.
• Exception review. The importer accepts the link and asks for an exception. The law requires full compliance with the importer guidance in the UFLPA strategy, complete and substantive answers to every CBP request, and clear and convincing evidence that the goods were not made wholly or in part with forced labor. CBP's Forced Labor Division handles it.

CBP's FAQ says clear and convincing evidence "generally means that a claim or contention is highly probable." Exceptions are also public: the law requires a report to Congress within 30 days, "identifying the good and the evidence considered."

The Records That Release a Detained Shipment

For an applicability review, CBP wants documentation "tracing the supply chain from the raw material stage to the finished, imported goods," made in the ordinary course of business. Its 2026 guidance lists the usual records: purchase orders, invoices, production contracts, work orders, bills of lading, foreign customs clearance declarations and waybills, transportation records, manifests, proof of payment and certificates of origin.

Two rules stand out. Affidavits and redacted or untranslated documents "are not sufficient for an applicability or exception review," and foreign-language documents should come with English translations. And if an importer "fails to provide information regarding the production of even a single supplier in the chain," CBP says the shipment "will be denied entry into the United States." For the high-priority sectors, the guidance adds what each file should show:

• Apparel. The whole chain from fiber "through yarn spinning, fabric manufacturing (weaving/knitting, dyeing, finishing), garment production (cutting, sewing, assembly), and final export," with every entity identified.
• Cotton. The supply chain "from the origin of the cotton at the bale level to the final production of the finished product," with a numbered flow chart and maps.
• Aluminum and copper. Certificates of origin or manufacturer's affidavits naming where each material was mined, smelted and manufactured; for aluminum, CBP also lists raw material invoices, purchase orders, proof of payment and production records. Affidavits go with the records, not in place of them.
• PVC. The chain "from the sourcing of raw materials (e.g., ethylene and chlorine) to the final production of the finished PVC product," and for PVC flooring, every layer.

An exception request also has to show a working due diligence system: supplier engagement, a supply chain map from raw materials, a written supplier code of conduct that forbids forced labor, training, monitoring, remediation and independent verification. Audits should be unannounced and run by independent auditors against the International Labour Organization's 11 indicators of forced labor; CBP says financial and environmental audits do not count.

Time depends on completeness. CBP's FAQ says it "cannot make a determination unless the document package is complete," and that "the average review period for a complete package is two to three weeks." For a supply chain identical to one CBP already cleared, a summary tracing report has brought detentions down to "an average of ten to 14 days." Those are CBP's averages, not a promise for any one shipment.

Where a Prep Center Fits

The UFLPA puts the burden on the importer of record. The customs broker files the entry for the importer, CBP sends the detention notice to the importer, and the supply chain records come from the brand and its suppliers. A prep center receives the freight after CBP releases it, so it sees the cartons, not the supply chain behind them. Our breakdown of who the importer of record is when a 3PL takes the container shows where each responsibility sits.

Release is not always the end. CBP can demand the return of released goods on CBP Form 4647 within 30 days of release, or up to 30 days after the conditional release period ends, whichever is later. The importer then has 30 days to return the goods to the port, and a failure to redeliver can cost liquidated damages of three times the entered value. That is one reason to know which warehouse received which cartons, and when.

PrepVia receives imported freight at our Miami warehouse, 8507 NW 72nd St, Miami, FL 33166, and routes it into Amazon FBA. Receiving and inspection are included, and discrepancies are reported within 24 hours of arrival, with photos. A receiving record shows what arrived and when; it does not show where the cotton, aluminum or copper inside a product came from. PrepVia does not trace the origin of inputs and does not offer lot-level recall tracking, so the supply chain file stays with the brand and its suppliers.

Frequently Asked Questions

What is the UFLPA Entity List?

It is the register DHS keeps of the four lists the Uyghur Forced Labor Prevention Act requires. CBP presumes that goods produced by a listed entity are made with forced labor and are not entitled to entry, unless the importer of record qualifies for an exception. As of October 29, 2026, it names 190 entities.

How many entities were added to the UFLPA Entity List in 2026?

Forty-six. A notice of August 3, 2026 (91 FR 48913) added 43 and put the list at 187. A notice of October 29, 2026 (91 FR 68159) added BGI Genomics, MGI Tech and Shenzhen BGI Technology, bringing it to 190.

If none of my suppliers is on the list, are my goods in the clear?

Not necessarily. The law also presumes forced labor for goods made wholly or in part in Xinjiang, whoever made them, and CBP says any input from Xinjiang, even a minor component from a tier 3 or tier 4 supplier, puts the finished product under the presumption. The notice also says the list is not exhaustive.

When does the presumption start for a newly listed company?

On the date the Federal Register notice is published, according to DHS. The two 2026 notices do not mention a grace period for goods in transit.

What happens if CBP detains a shipment under the UFLPA?

The importer has 30 days to request an applicability or exception review, or to export or destroy the goods, with at most two extensions and no more than 90 calendar days from the notice. The importer pays storage during the review, CBP may require a bond of three times the goods' value, and with no action in 30 days the shipment is deemed excluded.

What documents does CBP want to release a detained shipment?

Ordinary business records that trace the supply chain from the raw material stage to the finished goods, such as purchase orders, invoices, bills of lading, proof of payment and certificates of origin, with English translations. Affidavits and redacted or untranslated documents are not sufficient, and a gap at a single supplier makes the submission insufficient.

Is the UFLPA the same as the 2026 Section 301 tariff on forced labor?

No. The UFLPA decides whether goods may enter at all. The Section 301 action of July 28, 2026 (91 FR 47318) adds a duty, from July 24, 2026, on products of the economies USTR investigated for failing to impose and effectively enforce a ban on goods made with forced labor.

Final Take

The UFLPA Entity List is an English-language register that says it is not exhaustive, and in 2026 it moved twice. Checking supplier names against it is the first pass. The law follows the input to any tier, tier 3 and tier 4 included, and CBP releases detained goods on records that trace the chain to the raw material, with no supplier missing.

The purchase orders that will carry inventory through Chinese New Year 2027 are going out now. Map those supply chains, collect the records CBP lists, and keep them ready to send, because a gap costs less to close in November than at the port in February.