UFLPA: The U.S. Uyghur Forced Labour Prevention Act and Supply Chain Risks for Turkish Exporters

What is UFLPA and why is it relevant to Turkish manufacturers?

The Uyghur Forced Labor Prevention Act (UFLPA) was signed into law in the United States on December 23, 2021, and its core mechanism, the 'rebuttable presumption,' came into effect on June 21, 2022. The law presumes that goods produced wholly or partially in China's Xinjiang Uyghur Autonomous Region (XUAR) were produced through forced labor and prohibits their importation into the United States.

Although the law doesn't directly target Türkiye, its implementation closely affects Turkish exporters. The UFLPA looks at any link in the supply chain, not just the country of origin. This means a product manufactured in Türkiye and exported to the US could fall under the ban if the cotton, polysilicon, or other intermediate material it contains originates from Xinjiang. Simply bearing the "Made in Turkey" label does not provide protection.

This article is intended to inform manufacturers exporting textiles, solar panels, electronics, and automotive parts to the U.S.; it is not a legal opinion or certification service. The aim is to objectively explain how the law works and why supply chain traceability has become critical.

• Signature: December 23, 2021 — Effective date (rebuttable presumption): June 21, 2022.
• Legal basis: 19 USC § 1307 (prohibition of import of goods produced by forced labor).
• Implementing agency: U.S. Customs and Border Protection (CBP).
• The scope is not just the origin, but all layers of the supply chain: 'wholly or partially'.

How it works: rebuttable presumption

At the heart of the UFLPA is the 'rebuttable presumption'. This means that when the CBP inspects a product, it operates on the assumption that 'until proven otherwise, it was produced by forced labor'. The burden of proof rests entirely with the importer; it is the importer's, not the CBP's, responsibility to demonstrate that the product is clean.

This presumption is not easy to refute. For the CBP to grant an exception to this presumption, three conditions must be met simultaneously: the importer must have fully complied with the UFLPA guidelines and regulations; they must have responded completely and substantially to the CBP's requests for information; and it must be demonstrated with 'clear and convincing evidence' that the goods were not produced wholly or partly in Xinjiang or by a Listed Entity firm. This is a threshold of evidence far beyond ordinary customs documentation.

In practice, this means that goods may be detained at port, and the importer must respond by documenting the entire supply chain within a specified period. If sufficient evidence cannot be provided, the goods cannot enter the US; they will either be returned or destroyed.

• The assumption is against the importer: the burden of proof to the contrary rests with the importer.
• The threshold for proof is high: 'clear and convincing evidence' — a simple invoice/certificate of origin is not sufficient.
• Three conditions are required for an exception: full compliance with the guidelines + complete answers to the CBP questions + clear and convincing evidence.
• Goods that cannot be proven to be there are confiscated and their entry is denied; this results in commercial and reputational damage.

Which sectors and goods are priorities?

The CBP and the Forced Labour Enforcement Task Force (FLETF) concentrate their limited oversight resources on 'high-priority sectors'. The initial strategy, launched in June 2022, identified four sectors: apparel/textiles, cotton and cotton products, silica-based products (including polysilicon, an input for solar panels), and tomatoes and their derivatives.

The scope has steadily expanded since then. In July 2024, aluminum, PVC, and seafood were added. With a strategy update dated August 19, 2025, FLETF added five more sectors: caustic soda, copper, jujube, lithium, and steel. This expansion shows that the law now effectively touches not only textiles and solar panels, but also electronics, automotive, batteries, and construction inputs.

Being in a priority sector means there is a higher likelihood of being investigated; not being in a priority sector is not an exemption. The law applies to any goods coming from a firm on the Establishment List or having ties to Xinjiang.

• Top four (June 2022): ready-made clothing, cotton/cotton products, silica-based products (polysilicon), tomatoes.
• July 2024 additions: aluminum, PVC, seafood.
• 2025 update (August 19, 2025) additions: caustic soda, copper, jujube, lithium, steel.
• Higher priority = more frequent review; however, off-list sectors are not exempt from the law either.

UFLPA Entity List and continuous expansion.

The second pillar of the law is the UFLPA Establishment List. This list includes Chinese companies found to be linked to forced labor. Goods from a company on the list fall under the presumptive effect, regardless of industry and even if manufactured outside of Xinjiang.

The list is growing rapidly. The DHS announced on July 31, 2026, that it would add 43 new companies, bringing the total to 187; this represents an increase of approximately companies and the largest one-off expansion to date. The updated list was published in the Federal Register on August 3, 2026. Companies on the list span a wide range of sectors, including agriculture, batteries, electronics, food additives, household appliances, nonferrous metals, plastics, and textiles.

This expansion shifts compliance responsibility from a 'one-time check' to 'continuous monitoring'. A supplier who is clean today could become a source of risk tomorrow due to a newly added sub-supplier.

• Company List: 187 companies as of August 3, 2026 (43 companies added on July 31, 2026).
• Goods from the listed company are considered presumed even if they were produced outside of Xinjiang.
• Covered sectors include: agriculture, batteries, electronics, food additives, household appliances, non-ferrous metals, plastics, and textiles.
• The list is constantly expanding: supplier checks are not a one-off event, but continuous.

What should importers do: supply chain traceability

At UFLPA, the cornerstone of defense is supply chain traceability. The CBP guidance emphasizes that importers must map their supply chain and know all layers down to raw material suppliers. It's not enough to simply know the direct supplier; the entire chain is expected to be traceable, from the cotton field to the polysilicon quarry.

This is a document-based defense. The manufacturer must be able to document the entire supply chain from start to finish with raw material origin records, purchase invoices, production and shipment records, supplier statements, and, where possible, independent traceability/analysis evidence. These records must be ready before the CBP investigation begins; evidence gathered after detention is often insufficient under time pressure.

The operational equivalent of traceability is the supplier due diligence process: regular screening of suppliers and sub-suppliers against the Entity List, inclusion of origin and forced labor prohibition clauses in contracts, and the maintenance of an alternative sourcing plan for high-risk inputs.

• Map the supply chain all the way to raw materials; know all layers, not just the first-tier supplier.
• Prepare the necessary documents in advance: origin records, invoices, production/shipment records, supplier declarations.
• Regularly screen suppliers and sub-suppliers against the UFLPA Entity List.
• Include origin and forced labor prohibition clauses in contracts; plan for alternative sourcing for high-risk inputs.
• Keep traceability data verifiable (documented) — a statement alone does not constitute 'clear and convincing evidence'.

What does this mean for Turkish manufacturers?

The real risk for Turkish manufacturers lies not in their own country, but in the Chinese-origin intermediate goods and raw materials they use. Typical risk factors include Xinjiang cotton in cotton textiles, Xinjiang polysilicon in solar panels, and inputs such as batteries, copper, aluminum, or steel in electronics and automotive parts. Even if these inputs are processed and transformed into final products in Türkiye, they are considered 'partially' produced and may fall under presumptive protection.

The practical conclusion is this: access to the US market now depends as much on supply chain transparency as on product quality. Manufacturers using Chinese-sourced inputs must either be able to document that these inputs are unlinked from Xinjiang, or mitigate the risk from the outset by sourcing outside of Xinjiang/China. This applies to sectors as rapidly expanding as textiles and solar energy, as well as electronics, automotive, and construction input sectors.

This text is for informational purposes only and does not substitute for formal legal advice. For current high-priority sectors, the Entity List, and application details, always consult primary official sources (cbp.gov and dhs.gov); and for specific shipments, seek advice from a customs/trade law expert.

• Highest risk areas: Xinjiang cotton (textiles), Xinjiang polysilicon (solar panels), batteries/copper/aluminum/steel (electronics-automotive).
• ‘The 'partially' rule: Even if processed in Türkiye, input products originating from China/Xinjiang may still pose a risk.
• Act early: supply chain mapping and supplier screening should begin before ordering.
• Primary sources for the decision: cbp.gov and dhs.gov; seek expert legal advice on specific shipments.

Frequently Asked Questions

Does UFLPA only apply to imports directly from China?

No. UFLPA looks at the supply chain, not the country of origin. Even if a product is manufactured in a third country like Turkey, it may fall under the presumption of rebuttal if it contains an input that was 'wholly or partially' produced in Xinjiang or at a firm on the Establishment List.

What threshold is required to prove that my product is clean?

Before granting an exception to the presumption, CBP requires three conditions: full compliance with UFLPA guidelines, complete and substantial responses to CBP requests for information, and clear and convincing evidence that the goods were not produced under forced labor. This is a much higher threshold of evidence than a standard certificate of origin.

Which sectors are being prioritized for analysis?

The first four sectors (June 2022) were ready-made clothing, cotton/cotton products, silica-based products (including polysilicon), and tomatoes. These were followed by aluminum, PVC, and seafood (July 2024); then caustic soda, copper, jujube, lithium, and steel (updated August 19, 2025). Not being in a priority sector does not mean exemption.

How many companies are on the UFLPA Organization List?

According to the DHS announcement on July 31, 2026, and the updated list published in the Federal Register on August 3, 2026, there are 187 companies on the list (43 companies were added at that time). Because the list is constantly expanding, supplier screening needs to be ongoing.

I manufacture in Türkiye; am I still at risk?

Yes, you can. The risk doesn't come from your production location, but from the Chinese-sourced inputs you use. If you use inputs like Xinjiang cotton, Xinjiang polysilicon, or batteries, copper, or steel linked to the Establishment List, your product may be considered 'partially manufactured' and therefore at risk, even if you process it in Türkiye.

This content is for informational purposes only and does not constitute legal opinion or compliance assessment. Current official sources from the relevant country should be consulted for precise obligations.