UFLPA

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, […]

USTR Announces Section 301 Action Imposing New Tariffs on 60 Trading Partners 

The Office of the U.S. Trade Representative (USTR) has announced a new Section 301 action imposing additional tariffs of 10% to 12.5% on imports from 60 economies that fail to prohibit or effectively enforce bans on goods produced with forced labor. The action covers the top 60 U.S. trading partners, representing 99.4% of U.S. imports, and took effect July 24, 2026. U.S. Customs and Border Protection (CBP) has issued entry filing guidance in CSMS #69326983, including the applicable Chapter 99 tariff headings. 

Key Takeaways 

  • Effective July 24, 2026, USTR imposed additional Section 301 duties of 10% or 12.5% on imports from 60 economies covering 99.4% of U.S. imports, based on findings that these economies failed to adopt or effectively enforce forced labor import prohibitions. 
  • CBP issued entry filing instructions in CSMS #69326983, including the Chapter 99 headings (9903.05.20 through 9903.06.21), reporting sequence, and Foreign Trade Zone admission requirements. 
  • Goods entered duty free under USMCA (Canada and Mexico) are exempt, as are CAFTA-DR textiles and apparel, Section 232 articles, civil aircraft, pharmaceutical articles, informational materials, and donations. There is also a list of miscellaneous products exempt no matter what their country of origin. 
  • An in-transit exception applies to goods loaded and in transit on the final mode before 12:01 a.m. ET on July 24, 2026, and entered before 12:01 a.m. ET on July 28, 2026. 

Why USTR Took […]

Forced Labor Enforcement Just Crossed a Border: What CBP’s Serbia Copper WRO Means for Your Supply Chain

Key Takeaways 

  • CBP continues to chase the company, not just the country. Zijin’s parent was already on the UFLPA Entity List for forced labor in China; this Withhold Release Order (WRO) hits its Serbian copper operation on a separate evidentiary basis. Moving production to a “friendly” country does not move you out of CBP’s reach. 
  • Copper just joined the enforcement map. Forced-labor detentions are no longer concentrated in apparel, solar, and cotton. If you import copper—or anything containing it—your supply chain is now in scope, and most copper-reliant importers have done zero forced-labor due diligence. 
  • The burden is on you, and it lands the moment your shipment is detained. Under a WRO, there is no notice and no grace period. You either prove your goods are clean by detailed documentary evidence, or you export or destroy them. 

On June 16, 2026, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order against copper and copper products manufactured in Serbia by Serbia Zijin Copper D.O.O.—the fourth WRO of Fiscal Year 2026 and the second targeting a Serbian operation in roughly six months. Effective immediately, CBP personnel at every U.S. port of entry will detain shipments of copper and copper products from this company. 

If you read that as another distant enforcement headline, you are missing the part that should concern you. This […]

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 […]

DHS Announces New High Priority Sectors for UFLPA Enforcement

The Department of Homeland Security’s (DHS) Forced Labor Enforcement Task Force (FLETF) released an update to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China.

Strategy Background

DHS released the first publication of the UFLPA Strategy in June 2022. The strategy outlines a multi-pronged approach to combating forced labor in global supply chains.The strategy includes a comprehensive assessment of the risk of importing goods with forced labor in the PRC, high priority sectors for enforcement, guidance to importers, recommendations to accurately identify affected goods, and more. DHS released the first update to the publication in August of 2023.

The Latest Update  

The update builds on two years of the Administration’s enforcement of the UFLPA. The latest strategy identified new high priority sectors for enforcement – aluminum, polyvinyl chloride (PVC), and seafood. These industries were identified due to higher risk of forced labor or state labor transfer of Uyghurs and other ethnic minorities from the Xinjiang Uyghur Autonomous Region (XUAR).

Entities in these sectors will now be prioritized for review for enforcement actions such as inclusion on the UFLPA Entity List, sanctions, export limitations, and visa restrictions.

Other products previously identified as high priority such as apparel, cotton and cotton products, silica-based products including polysilicon, and tomatoes remain high priority sectors.

The latest updates also outline how the FLETF has significantly advanced their objectives through several initiatives, such as strong enforcement by U.S. Customs and Border Protection (CBP); expansion of the UFLPA Entity List; […]

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