By: Arthur Bodek

On October 2, 2024, the U.S. Department of Homeland Security announced the addition of two companies to the Uyghur Forced Labor Prevention Act (UFLPA) Consolidated Entity List and a technical correction to modify the name of one already listed entity.

By statute, goods, mined, produced, or manufactured wholly or in part in the XUAR or produced by an entity on one of the UFLPA lists are subject to a rebuttable presumption that they were made using forced labor and are inadmissible.

The two new additions to the entity list, effective October 3rd, are:

• Baowu Group Xinjiang Bayi Iron and Steel Co., Ltd. (also known as Xinjiang Bayi Iron and Steel Co. Ltd.; Baosteel Group Xinjiang Bayi Iron and Steel Co., Ltd.; and Bayi Iron and Steel).*

• Changzhou Guanghui Food Ingredients Co., Ltd. (also known as GSweet; Changzhou Guanghui Food Additive Co., Ltd.; and Changzhou Guanghui Food Technology Co., Ltd.; and formerly known as Changzhou Guanghui Biotechnology Co., Ltd.)**

In addition, the DHS modified its designation of the below already listed UFLPA entity:

• Changhong Meiling Co., Ltd. (formerly known as Hefei Meiling Co., Ltd.; and Hefei Meiling Group Holdings Limited)

Since the UFLPA was signed into law, 75 entities have been added to the UFLPA Entity List involving various product sectors. The full list can be found on the Homeland Security webpage. Future additions to the list will be considered. A procedure is also available whereby parties may request their removal from the entity list.

Please do not hesitate to contact any of our attorneys for further information on the above or any other aspect of UFLPA compliance.

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* Found to fall within the UFLPA category of entities working with the government of the Xinjiang Uyghur Autonomous Region (“XUAR”) to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the XUAR.

** Found to fall within the UFLPA category of facilities and entities that source material from the XUAR or from persons working with the government of Xinjiang or the Xinjiang Production and Construction Corps (“XPCC”) for purposes of the “poverty alleviation” program or the “pairing-assistance” program or any other government labor scheme that uses forced labor.