DHS publishes 2025 update on forced labor strategy
Date of publication: August 20, 2025
On August 19, 2025, the U.S. Department of Homeland Security (DHS) released its 2025 annual strategy update on the implementation of the Uyghur Forced Labor Prevention Act (UFLPA).
The initial strategy was published in June 2022 and there have been significant improvements made by both government and the trade toward ensuring that goods made with forced labor from the Xinjiang Uyghur Autonomous Region do not enter U.S. supply chains.
The UFPLA was enacted on December 23, 2021. The UFLPA charged the Forced Labor Enforcement Task Force (FLETF), chaired by DHS, to develop a strategy for supporting the enforcement of Section 307 of the Tariff Act of 1930, as amended (19 U.S.C. § 1307), to prevent the importation into the United States of goods mined, produced, or manufactured wholly or in part with forced labor in China.
Key updates and achievements
- Expansion of the entity list: The UFLPA Entity List, which identifies companies and facilities linked to forced labor, has grown from twenty entities in 2022 to 144 in 2025, with seventy-eight new additions since last year. All updates to the Uyghur Forced Labor Prevention Act Entity List, including any additions, removals, or technical corrections of entities are published in the Federal Register on a rolling basis, and made available to the public at DHS’s Uyghur Forced Labor Prevention Act Entity List webpage.
- New high-priority sectors: The Task Force has expanded its focus on high-risk industry sectors. Previously targeted industries included aluminum, apparel, cotton, polyvinyl chloride, seafood, silica-based products (including polysilicon), and tomatoes. For 2025, five new sectors were added:caustic soda, copper, jujubes (red dates), lithium, and steel. These sectors were selected based on credible evidence of forced labor risk, government investment priorities, and production concentration in Xinjiang. It should be noted that a number of these commodities are also of focus under the recent (and pending) Section 232 tariffs, including steel, aluminum, copper, and polysilicon. As a result, these commodities bring heightened attention from CBP with respect to enforcement actions. More robust attention to due diligence and compliance is necessary.
- Enforcement actions: Since the UFLPA’s rebuttable presumption went into effect in June 2022, U.S. Customs and Border Protection (CBP) has examined over 16,000 shipments valued at nearly $3.7 billion, detaining or excluding many that violated the Act, while facilitating legitimate trade. The most recent publicly available statistics on Uyghur Forced Labor Prevention Act enforcement can be found here. CBP has robustly enforced Section 307 of the Act, resulting in fifty-two active Withhold Release Orders and 9 Findings to date. This data can be found on CBP’s website.
- Collaboration and outreach: The Task Force has increased engagement with private sector companies, non-governmental organizations, and international partners to raise awareness, improve due diligence, and support compliance. Webinars and targeted outreach have been conducted, especially for sectors newly designated as high priority. The Commercial Operations Advisory Committee (COAC) Forced Labor Working Group has had consistent interaction with CBP to provide input and recommendations from the private sector, most recently with respect to improved guidelines for companies.
- Identification and reporting: The report details ongoing improvements in identifying entities and products linked to forced labor. Any FLETF member agency may submit a recommendation to add an entity to the Uyghur Forced Labor Prevention Act Entity List. Additionally, public input is encouraged via dedicated DHS email addresses (FLETF.UFLPA.EntityList@hq.dhs.gov), and the process for adding entities to the list has been streamlined. It should be noted that enhanced use of supply chain tracing technologies has contributed to improved identification and reporting of entities.
- Product list: An updated appendix in the strategy document provides a comprehensive list of products associated with entities on the UFLPA Entity List, ranging from textiles and apparel to chemicals, metals, and food products. This list can assist companies in identifying possible products that would pose elevated risk and the need for more robust due diligence.
Why it matters
The UFLPA and its enforcement strategy are designed to protect human rights, support fair competition for U.S. businesses, and strengthen national security by keeping goods made with forced labor out of American supply chains. The 2025 update demonstrates a whole-of-government approach, increasing transparency and accountability, and signaling to importers the importance of robust supply chain scrutiny, especially in high-risk sectors.
Under the current enforcement-focused approach by DHS/CBP, it is imperative that companies conduct ongoing due diligence surrounding the parties in their supply chains, including those in sub-tiers. Failure to do so may result in cargo detentions, seizures, supply chain disruptions, reputational damage, legal risks, and additional costs.
Conclusion
The U.S. government continues to intensify its efforts to combat forced labor in global supply chains, with expanded enforcement, more targeted industry focus, and increased collaboration with stakeholders. Businesses importing goods from China (as well as those with connections to China at sub-tiers), especially those in newly designated high-priority sectors, should review their supply chains and strengthen due diligence to ensure compliance with UFLPA requirements. The public and private sectors are encouraged to stay informed and participate in efforts to eliminate forced labor from international trade.
For more information on how ONESOURCE Global Trade solutions can assist you in managing supply chain risk and regulatory compliance, contact your Account Manager or Client Success Manager.