Coalition Urges Robust Enforcement Four Years After UFLPA Implementation

As global momentum grows for forced labour import bans, advocates call for new Entity List additions, stronger scrutiny of labour transfers, and action against third-country circumvention.

June 18, 2026

As the United States marks the fourth anniversary of the implementation of the Uyghur Forced Labor Prevention Act on June 21, the Coalition to End Forced Labour in the Uyghur Region calls on the U.S. government to strengthen enforcement to ensure rigorous implementation, particularly in light of the law’s growing global importance. 

The UFLPA remains the most effective regulatory tool globally for combating state-imposed Uyghur forced labour. Recent research found that the law has changed corporate behaviour by creating legal and financial consequences for noncompliance, prompting companies to trace supply chains more deeply and shift sourcing in sectors, including apparel, solar, automotive, tomatoes, PVC, and other high-risk industries. The evidence shows that companies will change their behaviour under the pressure of sustained enforcement.

Despite this progress, the Coalition is concerned that UFLPA enforcement is not keeping pace with the evolution of state-imposed forced labour in China. The UFLPA Enforcement Statistics Dashboard shows a decline in CBP enforcement activity in recent months, when facts on the ground demand an uptick. No new entities have been added to the UFLPA Entity List since January 15, 2025, despite ongoing evidence of state-imposed forced labour. Any gap in enforcement leaves both Uyghurs vulnerable and allows forced labour products to enter international markets.  

“Corporations have a strong incentive to comply with the UFLPA only if they believe that cheating will get them caught,” said Scott Nova, Executive Director of the Worker Rights Consortium. “This is why the pace and strength of the U.S. government enforcement is the linchpin.”

“No entity has been added to the UFLPA Entity List in well over a year,” said Dean Pinkert, Special Advisor at Corporate Accountability Lab. “A static list deprives importers of critical supply-chain risk information and, equally important, forecloses broad use of the UFLPA’s rebuttable presumption to hold companies accountable for trade in goods that are tainted by their connection to state-sponsored labour transfer programs.” 

The Coalition urges the U.S. government to strengthen UFLPA implementation by:

• Adding new entities to the UFLPA Entity List based on available evidence;
• Increasing scrutiny of companies linked to state-imposed labour transfers, including transfers outside the Uyghur Region;
• Addressing third-country rerouting, transhipment, and supply-chain circumvention;
• Expanding high-priority sectors to reflect current research and enforcement risks, including automotive, pharmaceuticals, electronics, minerals and metals such as titanium, beryllium, gold, and magnesium, and other exposed sectors;
• Requiring importers to trace supply chains to the raw-material level;
• Increasing transparency around enforcement trends, detention, and release decisions;
• Ensuring that UFLPA enforcement remains evidence-based and independent of broader U.S.-China relations.

The UFLPA – which builds on Section 307 of the Tariff Act to cover certain instances of state-imposed forced labour – has set a global benchmark for responding to state-imposed forced labour and an important precedent for emerging forced labour import-ban legislation in other jurisdictions. United States-Mexico-Canada Agreement (USMCA) discussions are ahead, with Canada having recently introduced legislation to strengthen its domestic law. Other jurisdictions have adopted laws, such as the European Union, Pakistan, and Indonesia, and are moving toward implementation. In turn, other jurisdictions are considering new forced labour import bans and modern slavery legislation. 

Given the U.S. Trade Representative’s recent findings that more than 60 countries do not have or do not adequately enforce bans on goods made with forced labour, robust U.S. enforcement of the UFLPA is especially important. Additionally, the United States should use a diplomatic approach to encourage comparable laws and strengthen collaboration on meaningful enforcement, cross-border information sharing, and rebuttable presumptions where state-imposed forced labour is established.

“The UFLPA was one of the first major pieces of U.S. legislation to recognize and respond to the realities of Uyghur forced labour, demonstrating to Uyghur communities across the country that policymakers were hearing our voices and taking action,” said Misran Dolan, President of the Uyghur American Association. “Continued robust enforcement is not only essential to keeping goods tainted by forced labour out of U.S. markets – it is also a recognition of the suffering endured by Uyghurs who were subjected to these abuses, including many survivors and family members who now call the United States home.”

The Coalition to End Forced Labour in the Uyghur Region calls on the administration, Congress, and enforcement agencies to ensure that the fourth anniversary of the UFLPA marks a renewed commitment to preventing goods made with Uyghur forced labour from entering U.S. markets. The UFLPA’s impact depends on whether the U.S. government continues to enforce it with urgency, transparency, consistency, and independence.

Photo by Josh Young on Unsplash