forced labor compliance

China Blacklists Six U.S. Supply Chain Tracing Providers: What UFLPA Importers Need to Know

On August 5, 2026, China’s Ministry of Commerce placed six U.S. supply chain due diligence entities on its countermeasure list and prohibited organizations and individuals in China from transacting or cooperating with them. The six include the DNA tagging, isotopic testing, supply chain mapping, and labor audit providers that many importers rely on to document origin when U.S. Customs and Border Protection (CBP) detains goods under the Uyghur Forced Labor Prevention Act (UFLPA). Importers in cotton, apparel, electronics, minerals, and other UFLPA high-priority sectors should treat this as a direct hit on their evidence chain and act now. 

Key Takeaways 

  • On August 5, 2026, China’s Ministry of Commerce (MOFCOM) issued Order No. 2 of 2026 placing six U.S. entities on its countermeasure list under the Anti-Foreign Sanctions Law: Applied DNA Sciences, Inc.; Stratum Reservoir, LLC; Altana Technologies, Inc.; Responsible Business Alliance; Verite Group, Inc.; and Human Rights in China. 
  • The countermeasure prohibits organizations and individuals within China from engaging in relevant transactions, cooperation, and other activities with the six entities, effective August 5, 2026. The order imposes no asset freeze and no entry ban. 
  • MOFCOM’s spokesperson tied the package to the July 31, 2026 addition of 43 entities to the UFLPA Entity List, published in the Federal Register on August 3, 2026, which brought the list to 187 entities. 
  • The listed entities include providers of DNA tagging, […]

CBP Just Rewrote the Forced Labor Rulebook: What the New Operational Guidance Means for Importers

Short summary: On June 9, 2026, CBP issued new guidance supplementing its 2022 UFLPA guidance and other resources with a single document covering every forced-labor authority it enforces. The new guidance outlines CBP’s detention and exclusion processes and gives practical guidance on how to respond.


On June 9, 2026, U.S. Customs and Border Protection (CBP) published its new Forced Labor Enforcement Operational Guidance for Importers (Publication No. 5560-0526). It is not a refresh. It updates the June 13, 2022, UFLPA Operational Guidance for Importers and, for the first time, consolidates all forced-labor enforcement authorities CBP wields into a single 89-page reference. 

That consolidation is the story. Until now, importers had to stitch together separate sources to understand how the Uyghur Forced Labor Prevention Act (UFLPA), Withhold Release Orders and Findings under 19 U.S.C. § 1307, and the Countering America’s Adversaries Through Sanctions Act (CAATSA) actually differ in practice. CBP has now mapped all of them — including the exact timelines, the review paths, and the documentation bar — in one place. The practical effect: ignorance of the process is no longer a defensible position. 

The one-line summary every importer needs 

CBP detains or excludes goods it suspects were made, wholly or in part, with forced labor — and the burden is on you to prove they weren’t, on a clock that can […]

CBP Launches New Forced Labor Portal 

On January 21, 2026, Customs and Border Protection (CBP) launched its new Forced Labor Portal. The Portal provides a central system for submitting review requests for shipments detained or excluded for forced labor enforcement.

Effective, January 21, 2026, importers MUST use the portal to submit the following for review:

  • Withhold Release Order/Finding admissibility reviews.
  • Uyghur Forced Labor Prevention Act applicability reviews.
  • Uyghur Forced Labor Prevention Act requests for exception; and
  • Countering America’s Adversaries Through Sanctions Act exception requests.

All detained or excluded shipments requiring review must be submitted through this Portal, and users must have a login.gov account to access it. Depending on the type of review submitted, submission will be reviewed by CBP personnel in Forced Labor Division, or Port of Entry, or the Center of Excellence and Expertise.

Diaz Trade Law has confirmed with CBP that responses to CBP Form 28 (Request for Information) and CBP Form 29 (Notice of Action) should not be submitted through the Forced Labor Portal.

The Portal is available at https://flportal.cbp.gov/s/login/ and CBP has provided an instructional video on how to submit a request here.

This change reflects another step forward in how CBP interacts with the trade community, transitioning from […]

DHS Adds Additional UFLPA High-Priority Sectors; Releases UFLPA 2025 Strategy Update

Learn more about this update and all things UFLPA at our upcoming forced labor webinar on Sept. 17, 2025. Register here.

On August 19, 2024, the U.S. Department of Homeland Security (DHS) announced that it would be adding steel, copper, lithium, caustic soda, and red dates to the list of high-priority sectors for enforcement under the Uyghur Forced Labor Prevention Act (UFLPA). DHS also announced the release of an update to the UFLPA enforcement strategy.

Addition of High-Priority Sectors

Under the UFLPA, DHS is tasked with identifying high-priority sectors for enforcement. A high-priority sector designation indicates that entities in the sector have a higher risk of forced labor or state labor transfer of Uyghurs and other ethnic minorities from Xinjiang. 

In making the announcement of additional sectors, DHS cited each new addition’s connections to forced labor risks. For example, DHS stated that steel and copper have both been government-backed investment focal points in Xinjiang. Similarly, lithium is a government-identified key sector for investment and development in Xinjiang.

UFLPA Enforcement Strategy Update

DHS serves as the chair of the Forced Labor Enforcement Task Force (FLETF). Each year, the task force updates the UFLPA’s Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China (UFLPA Strategy). The task force is statutorily required to provide annual updates […]

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