How to check a supplier against the UFLPA Entity List
The Uyghur Forced Labor Prevention Act changes the burden of proof at the U.S. border. The list at its center is simpler than most guides suggest — and that simplicity is exactly what makes a careless check miss things.
The rebuttable presumption — the part that matters most
The Uyghur Forced Labor Prevention Act (UFLPA), in effect since June 2022, creates a rebuttable presumption: goods mined, produced, or manufactured wholly or in part in China's Xinjiang region — or produced by an entity on the UFLPA Entity List — are presumed to have been made with forced labor and are barred from entry into the United States. The burden is on the importer to prove otherwise with clear and convincing evidence, which is a meaningfully higher bar than most import compliance checks. In practice, U.S. Customs and Border Protection can detain a shipment first and ask the importer to prove it's clean second.
What the official list actually contains
The UFLPA Entity List is a page on dhs.gov, maintained by the Forced Labor Enforcement Task Force. Read on 2026-09-11, it showed Last Updated 07/31/2026, and the newest entries carried an effective date of August 3, 2026. DHS's announcement of those additions put the list at 187 entities.
- Two columns, nothing else: Name of Entity and Effective Date. No address, no registration number, no country field.
- Sub-lists by type of conduct. The entities are grouped under the Act's categories, and the category for exporters currently reads “We have not identified additional exporters at this time.”
- Names in English. Our copy of the page from 2026-09-11 contains no Chinese characters, so a supplier you know by its Chinese name has to be checked through its English name.
- Aliases are written inside the name cell, in several phrasings — among them “including one alias:”, “including three aliases:”, “also known as” and “formerly known as”, the last covering companies that have been renamed.
What follows is the practical point: the name is the only field there is to match on. A check that compares only the headline name misses an alias; one that ignores “formerly known as” misses a company that renamed itself. A match is a lead to investigate, not a determination — and a no-match is only as good as the alias handling behind it. Parsing the list in code has traps of its own — the same entity listed in several categories, spelled differently, with its aliases on only one copy — measured in The UFLPA Entity List as Data.
What a real pre-shipment check needs to cover
- Whether the supplier, manufacturer, or any known upstream party appears on the UFLPA Entity List — including under any alias or former name.
- Whether the same party appears on other federal denied-party or restricted-party lists (the Consolidated Screening List), since forced-labor and export-control risk often overlap in practice.
The official sources are published separately — the UFLPA Entity List by DHS, the Consolidated Screening List by trade.gov — and checking one does not check the other: the Consolidated Screening List combines lists of the Departments of Commerce, State and the Treasury, and the UFLPA Entity List is not among them. Either can change after your last check. The UFLPA list's own Effective Date column and dhs.gov announcements are the record of when it changed.
What a name screen cannot tell you
Screening a supplier's name answers one question. Several forced-labor rules turn on something else entirely:
| rule | turns on | can a name screen settle it? |
|---|---|---|
| UFLPA Entity List | who produced the goods | It can flag a listed name. It cannot prove the absence of a listed party upstream. |
| Subsidiaries and affiliates of a listed entity | whether DHS named them, or attached “subsidiaries” or “affiliated entities” to a listed name | Only for names on the list. Otherwise, per DHS's FAQ, their goods “would not automatically be subject to the rebuttable presumption.” |
| BIS Affiliates Rule (Commerce Department Entity List, not UFLPA) | whether a party is an affiliate of certain entities on BIS's Entity List | No — an affiliate does not have to be named on the list. The rule (90 FR 47201, September 30, 2025) is stayed from November 10, 2025; BIS says the suspension “is set to end November 9, 2026, absent a future extension.” |
| UFLPA Xinjiang presumption | where the goods or their inputs were made | No. It depends on the supply chain, not the supplier's name. CBP's UFLPA Region Alert in ACE, deployed March 18, 2023, gives importers an early notice when goods may have been produced in Xinjiang. |
| Withhold Release Orders (Section 307) | specific products and producers named in CBP orders | No — not on the lists above. |
| Section 301 forced-labor duties (since 2026-07-24) | the country of origin — 60 economies | No. It is a duty set by origin, with exemptions; see CBP's guidance. |
What “no match” should — and shouldn’t — tell you
A “no match” result is not a guarantee that a shipment or supplier is free of forced-labor or trade-enforcement exposure. It means the specific sources checked didn't return a match at the time you checked. A screening tool should tell you which sources it queried and when, so you can tell “checked and clear” apart from “not checked.”
How Aervik Labs' US Import Risk Screening API handles this
Send a supplier or manufacturer name and get back a UFLPA Entity List match and a Consolidated Screening List (denied-party) match in one call, plus a deterministic overall exposure rating — a fixed calculation, never an AI judgment, so the same inputs always produce the same rating. A batch endpoint screens up to 50 parties at once, and every response says, per source, whether it reflects a live government data call.
It screens names; it does not classify goods. An HTS number and country of origin are optional and echoed back as your own input — they are not used to screen anything. Determining the tariff line for a shipment is a licensed customs broker's work. The API does not report antidumping or countervailing duty scope (removed in September 2026 — for that, use the ITA's own search), and it does not assess the Section 301 duties above. Nothing on this page is legal or customs advice.
See the full US Import Risk Screening API
Further reading: the rest of Aervik Labs' trade intelligence products.