DHS Identifies 43 Companies Associated With Forced Labor

Aug. 3, 2026
By: Pietro N. Bianchi

The Department of Homeland Security (“DHS”), on behalf of the Forced Labor Enforcement Task Force (“FLETF”), announced the single largest-ever expansion of the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List. The UFLPA establishes a rebuttable presumption that imports made (in whole or in part) in the Xinjiang Uyghur Autonomous Region (“XUAR”) of China are made from forced labor. The UFLPA extends to entities that recruit, transport, transfer, harbor, or receive forced laborers out of the XUAR. Goods presumed to be made with forced labor are not permitted to enter the U.S. DHS added 43 entities, with products ranging from foods to aluminum to pharmaceuticals, to the UFLPA Entity List, bringing the total to 187 entities.

While UFLPA’s goal is to address violations of human rights, DHS Secretary Mullin’s statements concerning the Entity List expansion focuses on the harm to U.S. commerce: “The American worker must not be undercut and cheated by foreign companies that use slave labor. Our job is to defend the Homeland, and that includes protecting our citizens from unfair competition that not only disadvantages Americans, but harms human dignity.”

The DHS action comes in the wake of the USTR’s determination in its Section 301 forced labor investigation. DHS Secretary Mullin’s statements are aligned with the investigation’s finding that the uneven enforcement of bans (or a lack of bans) on goods made with forced labor unfairly disadvantages U.S. commerce. The DHS’ orientation toward commercial security is further reinforced by the announcement’s observation of the Trade Fraud Task Force, which recently published a guide that discusses common fraud typologies and the tools it intends to use to punish trade fraud.

All told, the Trump Administration appears to be reaccelerating forced labor enforcement to further its goal of onshoring manufacturing. Importers should strongly consider developing (or revamping) customs compliance procedures as ordinary business tasks, mapping out upstream suppliers, and reviewing importation documents. If you have questions about due diligence, Forced Labor, or Section 301 tariffs do not hesitate to contact an attorney at Barnes Richardson, & Colburn LLP.