2025 UFLPA Enforcement Trends: Insights from Trade Data

In 2025, enforcement of the Uyghur Forced Labor Prevention Act (UFLPA) reached unprecedented levels, with U.S. Customs and Border Protection (CBP) adding 47 new entities—primarily in China—to the UFLPA Entity List. The crackdown reflects heightened scrutiny of global supply chains, particularly in sectors like textiles, solar energy, and mining. This article outlines key enforcement developments, sector-specific trends and geopolitical context. Here’s what you need to know about how to comply with UFLPA regulations.

A Record Year for UFLPA Enforcement

This year, U.S. Customs and Border Protection (CBP) has added 47 new entities to the UFLPA Entity List. These are companies believed to be linked to forced labor in China’s Xinjiang region, and their goods are presumed to be produced with forced labor under the UFLPA.

Of the 47 entities:

• 46 are based in China, with deep operational links to Xinjiang
• 1 is based in Vietnam, signaling growing attention on transshipment and global distribution routes
• The most impacted sectors include: Textile & Apparel, Solar Energy & Polysilicon, and Mining & Raw Materials.

Sector-Wise Insights from the 2025 Entity List

The companies added in 2025 are not just random names—they reflect clear enforcement patterns aligned with trade intelligence, activist investigations, and geopolitical concerns. Let’s break down the sectors most affected this year.

Textiles & Apparel: Still Ground Zero

More than half of the newly banned entities—over 25 companies—belong to the textile and apparel industry. This includes cotton ginning operations, fiber processors, yarn spinners, dyeing mills, and vertically integrated fabric producers.

Among the most prominent additions are subsidiaries of Huafu Fashion Co., Ltd., one of the world’s largest yarn producers, including:

• Awati Huafu Textile Co., Ltd.
• Shihezi Huafu Hongfeng Cotton Industry Co., Ltd.
• Xinjiang Huafu Color Spinning Group Co., Ltd.
• Ninghai Huafu Textile Co., Ltd.

These companies are involved in high-volume cotton processing and are closely linked to Xinjiang operations, even when incorporated in other provinces. Their inclusion shows just how pervasive the reach of Xinjiang-linked materials is across China’s textile ecosystem.

Solar Energy: Clean Energy, Clouded Supply Chains

2025 saw an expansion of enforcement into the solar and clean energy sectors, with at least 6 entities tied to solar materials and silicon production now blacklisted. These include:

• Shuangliang Silicon Materials (Baotou) Co., Ltd.
• Jiangsu Meike Solar Technology Co., Ltd.
• Baotou Meike Silicon Energy Co., Ltd.
• Donghai JA Solar Technology Co., Ltd.
• Hongyuan Green Energy Co., Ltd.
• Hongyuan New Materials (Baotou) Co., Ltd.

Several of these companies are based outside Xinjiang but maintain key supply relationships or facilities tied to the region.

Mining & Metals: Enforcement Moves Upstream

For the first time, the UFLPA Entity List is seeing multiple entries from the mining and raw materials sector. Companies such as:

• Zijin Mining Group Co., Ltd.
• Xinjiang Zijin Nonferrous Metals Co., Ltd.
• Xinjiang Zhongtai Group Co., Ltd.
• Xinjiang Zhongtai Chemical Co., Ltd.

These firms are involved in the mining, refining, and processing of critical materials—like zinc, copper, and chemicals—used in electronics, batteries, and industrial goods.

It’s no surprise that 46 of the 47 entities are China-based. However, the appearance of a Vietnamese entity on the 2025 list signals a strategic pivot. This means enforcement is no longer geographically confined. If you’re importing from Vietnam, Thailand, or Malaysia, you still need to ask: How to ensure supply chain transparency in 2025?

Political Winds Are Reinforcing Enforcement

With Donald Trump reemerging as a dominant political voice in 2025, the tone around the U.S.–China trade has grown even sharper. Trump’s legacy of aggressive tariffs and his administration’s original momentum behind confronting forced labor in Xinjiang continue to influence policy. That means UFLPA regulation isn’t just here to stay—it’s likely to intensify.

Why Trademo Map Is Built for This Moment

Unlike traditional compliance systems that stop at your Tier-1 vendors, Trademo Map traces your upstream supply chain as well as downstream supply chain back through Tier-2, Tier-3, Tier-4, and beyond—identifying hidden links to entities banned under the UFLPA.

It’s not just list-checking. Trademo Map helps you:

• Discover direct and indirect exposure to companies on the UFLPA Entity List
• Trace shipments that pass through Xinjiang or are connected to banned suppliers
• Monitor your entire upstream network in real time for new UFLPA additions
• Detect transshipment attempts—e.g., goods routed through Vietnam or other countries to obscure origin
• Map ownership structures that reveal whether a seemingly clean supplier is linked to a UFLPA-listed parent

Ready to Ensure UFLPA Compliance, End to End?

If you’re importing from high-risk sectors like textiles, solar, or raw materials—or simply want to be sure your supply chain won’t trigger UFLPA enforcement—Trademo Map makes you aware about the upstream supply chain challenges and solutions.

To explore how Trademo Map helps you comply with UFLPA and protect your global operations by ensuring supply chain visibility.

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