See the following message from Sidley Austin LLP regarding the Forced Labor Enforcement by the Department of Homeland Security.
On Friday afternoon, the Department of Homeland Security announced that the Forced Labor Enforcement Taskforce (FLETF) is adding 43 entities to the Uyghur Forced Labor Prevention Act (UFLPA) entity list.
This is the first action by FLETF during the second Trump administration (and may be an effort to show the world that the United States is serious about forced labor enforcement after it imposed tariffs on imports from 60 jurisdictions last week purportedly because those jurisdictions have not adopted U.S.-style forced labor laws and/or have not enforced them to U.S. standards).
Effective, Monday, August 3, 2026, U.S. Customs and Border Protection will apply a rebuttable presumption that articles produced by these entities were produced with forced labor and are, therefore, prohibited from entry into the United States. The listed entities are from a variety of industries, including pharmaceuticals, aluminum, gold, copper, lithium, textiles, food products, and others.
Many of these companies appear to produce raw/intermediate materials that could be in a company’s extended supply chain (i.e., given what they produce, these companies may not be a direct supplier, but could be a supplier to a supplier, etc.).
All companies should review the list of companies (including the entity-specific information FLETF provided) to confirm whether any of these entities are in their supply chain. There has been a significant increase in customs-related enforcement, including forced labor-related enforcement, in recent months. We expect this trend to continue/intensify.
If you have any questions, please contact our office.
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