TRUMP ADMINISTRATION TRADE ALERT – IMPORTS
HEADLINE	New Sectors Designated as High-Priority Enforcement Under UFLPA
DATE	August 19, 2025
AGENCY	Department of Homeland Security, along with the Departments of Labor, State, Treasury, Justice, and Commerce; Customs and Border Protection; U.S. Trade Representative
EFFECTIVE DATE	August 19, 2025
BACKGROUND	The 2021 Uyghur Forced Labor Prevention Act (“UFLPA”) established a rebuttable presumption that goods produced wholly or in part in the Xinjiang Uyghur Autonomous Region (“XUAR”) of China or by an entity on the UFLPA Entity List are made with forced labor and prohibited from importation into the U.S.   The UFLPA created the Forced Labor Enforcement Task Force (“FLETF”), which is led by DHS and adds entities and sectors to enforcement.   The initial high-priority sectors for UFLPA enforcement were apparel, cotton, tomatoes, and polysilicon. In 2024, the FLETF added polyvinyl chloride (PVC), aluminum, and seafood.
DETAILS	The Department of Homeland Security has added 5 sectors to the high-priority sector list for UFLPA enforcement: • Steel • Copper • Lithium • Caustic soda • Red dates This is in addition to the previously identified high-priority sectors: • Cotton, cotton products, apparel • Tomatoes & their downstream products • Silica-based products including polysilicon • Aluminum • Polyvinyl chloride (PVC) • Seafood A high-priority sector designation indicates that entities/goods in that sector have a higher risk of forced labor and/or sourcing from the XUAR, and indicates a higher likelihood of enforcement or inquiry from CBP.   The Trump Administration has increased detentions and enforcement actions, and fewer releases, under the UFLPA: • CBP’s published statistics show that from FY 2022 – 2024, roughly 53% of shipments were released (5,353 out of 10,142). • In FY 2025, only 6.5% of shipments have been released (430 out of 6,613). • FY 2025 has seen an increase in total detained shipments (2023: 4,016) (2024: 4,597) (2025: 6,613), with a substantial increase of enforcement in the automotive and aerospace sectors.   Should importers find their shipments detained, they must either demonstrate their importation is outside the scope of the UFLPA because it has no nexus to Xinjiang or a UFLPA entity, or present substantial “clear and convincing” evidence to rebut the presumption that the detained goods are made with forced labor and demonstrate (1) that the company has a robust due diligence & compliance system, (2) that the company engages in supply chain tracing and can trace their supply chains to the raw materials, and (3) that there is no Xinjiang sourcing/forced labor used throughout the entire supply chain.
BASIS	Uyghur Forced Labor Prevention Act (Pub. L. 117-78) (Dec. 23, 2021); 22 U.S.C § 6901
HTS/  PRODUCTS	Products of steel, copper, lithium, caustic soda, red dates.
COUNTRY	China; Xinjiang Uyghur Autonomous Region
CITE	DHS Press Release – Trump Administration Fights for America’s Economic and National Security, Designating New Chinese Industry Sectors as High-Priority for Enforcement under the Uyghur Forced Labor Prevention Act | Homeland Security   DHS Report to Congress – 2025 Updates to UFLPA Strategy (High-Priority Sectors) Report   DHS Fact Sheet – 2025 Updates to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China | Homeland Security

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