Fashion & Apparel · The Record
DHS adds 43 firms to the forced labor entity list, 41 of them under its sourcing sub-list
The Federal Register notice records forty-three additions to the UFLPA Entity List, two of them on two sub-lists; The Dallas Express reported the update takes the list to 187 entities, a 30% increase. Four of the additions reach U.S. apparel importers, by Kelley Drye's count.
The document that decides what a cotton shirt has to prove at a United States port is not a hangtag or a mill audit. It is an appendix to a Federal Register notice. That notice, "Notice Regarding the Uyghur Forced Labor Prevention Act Entity List," carries document number 2026-15628 and announces the publication of the list "updated as of August 3, 2026." The update, the notice states, "adds forty-three new entities to the UFLPA Entity List, two of which appear on two separate sub-lists."
The announcement that carried the update into the trade press was framed as a border promise. The Dallas Express report sets out three quotations in support of it: that "Today we are adding 43 Chinese companies to the Uyghur Forced Labor Prevention Act Entity List, and DHS will ensure their products do not enter our country"; that "The American worker must not be undercut and cheated by foreign companies that use slave labor"; and that "The Trump Administration remains steadfast in its commitment to remove forced labor from U.S. supply chains and to holding foreign companies accountable for their exploitation." The report attaches no speaker to any of the three. Enforcement begins August 3, 2026, when U.S. Customs and Border Protection applies a rebuttable presumption barring goods from the listed companies, The Dallas Express reported. Those words reach this desk only through that outlet's report; dhs.gov returned an error to our fetcher, so neither the wording nor the identity of whoever said it has been checked against the agency's own release.
The statute the notice runs on is older than the pledge. Since June 21, 2022, the notice states, the UFLPA has required the CBP Commissioner to apply a rebuttable presumption that goods produced by listed entities are made with forced labor and are therefore barred from importation under 19 U.S.C. 1307. What the August update changes is who sits under which sub-list, and that is where an apparel supply chain reads differently from the announcement. Forty-one of the forty-three go onto the section 2(d)(2)(B)(v) list, which the notice describes as identifying "facilities and entities that source material from the Xinjiang Uyghur Autonomous Region" or from persons working with the regional government or the Xinjiang Production and Construction Corps under government labor schemes. Kelley Drye & Warren's trade monitor counts four entities added under the separate list of entities working with the government of Xinjiang.
Nineteen of the forty-three additions are located outside of Xinjiang, Kelley Drye states. Separately, the Customs & International Trade Law Blog describes newly listed companies as headquartered outside the Xinjiang Uyghur Autonomous Region, in provinces such as Shandong, Jiangsu and Henan; that post does not say those are the same nineteen. Either way the addresses point at the spinning, trading and processing tier a brand rarely contracts with directly. The blog's instruction to importers is to screen direct suppliers and map upstream tiers against the consolidated list, because "the risk in most UFLPA cases sits several levels above the vendor named on the commercial invoice." A first-tier audit at a cut-and-sew factory does not reach that level.
The sector arithmetic cuts against the way this listing has been read in fashion. Kelley Drye states that four listed entities impact U.S. textile and apparel importers, and describes the additions as cutting across pharmaceutical products, food products, textile and apparel products, and metals and minerals products. The Dallas Express reported that the newly listed companies operate in aluminum, apparel, copper, cotton, and tomatoes and downstream products; OFW Law, which called the update "the single largest-ever expansion of the List," lists the sectors as aluminum, apparel, copper, cotton, food, pharmaceuticals and others. The appendix itself carries at least six names a sourcing manager would read as textile-adjacent: Aksu Huafu Color Spinning Co., Ltd.; Henan Tongzhou Cotton Industry Co. Ltd.; Shandong Weiqiao Textile Technology Co., Ltd.; Fujian Septwolves Industry Co., Ltd.; Anhui Xinya New Materials Co., Ltd.; and Shandong Weiqiao Pioneering Group Co., Ltd. The distance between six recognisable textile names and a count of four that reach apparel importers is a question about which listings actually bite at the border, and neither document resolves it. In each case the listing is an administrative designation that triggers a presumption the notice itself calls rebuttable, and OFW Law describes how an importer answers one: showing by "clear and convincing evidence" that the goods are not produced, wholly or in part, with forced labor, showing compliance with the importer guidance in the UFLPA Strategy, and answering CBP's requests for information. That is a border procedure, not an adjudicated finding against any of the six.
Against a growing list, the enforcement record for apparel is moving the other way. An analysis of CBP's UFLPA dashboard published by Due Diligence Design records 377 apparel shipments detained in the first half of 2025, fewer than half the 876 recorded for all of 2024. Detentions across all sectors went the opposite way: 6,636 in the first half of 2025 against 4,619 for all of 2024. The share of detained shipments that cleared fell from 34.9% in 2024 to 26.9% in that period, and the share of Chinese shipments denied entry rose from 61.6% to 77%. Apparel detentions are concentrated on China at 66.3%; Vietnam fell to less than 1% of apparel detentions from 23% in 2024, and no apparel shipments from Bangladesh had been detained in 2025 as of the analysis. OFW Law puts the programme's running total at more than 24,300 shipments blocked, worth nearly $1 billion. These detention figures are a third-party reading of CBP's public dashboard covering January to June 2025, not agency figures for the current year.
View the data
| Value (shipments) | |
|---|---|
| 2024, full year | 876 shipments |
| 2025, first half only | 377 shipments |
Source: Due Diligence Design analysis of CBP's UFLPA dashboard (third party, not CBP directly) · Daily Pol graphic
Analysis, from the figures above: the list is growing by 30%, on the Dallas Express count, while apparel detentions - measured as a half-year 2025 count set against a full-year 2024 total, a comparison of unequal periods that the analysis itself draws and that full-year 2025 data would be needed to settle - are running at less than half the prior year's. Two readings fit. Either the presumption has already moved cotton sourcing, which the Vietnam and Bangladesh figures complicate as much as they support, or enforcement attention has shifted toward the sectors the same dashboard ranks around apparel: automotive, consumer products and electronics, with agriculture fifth. Both firms advising importers here point the same way on exposure. Kelley Drye tells importers to "conduct traceability analyses of their key product supply chains," and the customs blog tells them to map upstream tiers.
This piece carries no response from the six companies named above. No request for comment had been sent when it was drafted, and this desk records the request rather than implying one. Reported reactions from the Chinese government and from Chinese industry bodies appear in no source this piece could fetch and quote, so they are not characterised here.
What can be checked next has dates on it. CBP applies the presumption to goods from these entities from August 3, 2026, and the dashboard that produced the 2025 figures publishes detentions by sector, so the first quarters of enforcement under the enlarged list will be readable there. This desk's falsifiable call: when full-year 2025 apparel figures are published on that dashboard, apparel detentions for 2025 will come in below the 876 recorded for 2024 - checkable by March 31, 2027. The narrower test, and the one closer to the garment, is whether any of the six textile names in the August appendix turns up in a detention statistic, or whether the four entities Kelley Drye counts as touching apparel importers remain the only ones that do.