The complexities of complying with the Uyghur Forced Labor Prevention Act (UFLPA) continue to challenge companies operating in global markets. Just trying to keep current with enforcement changes is difficult, but staying ahead of them must be the goal to ensure compliance and supply chain resilience.
Nearly every industry — from automotive and electronics to fashion and agriculture — must be vigilant today about forced labor in the supply chain. The stakes for noncompliance are too high to ignore, including costly fines, shipping delays, and reputational damage.
Exiger hosted an expert webinar that focused on key UFLPA enforcement trends, strategies, and the importance of a proactive, risk-based approach for compliance. Some key takeaways from the discussion are explored below.
[WATCH ON-DEMAND: Navigating UFLPA Enforcement: Strategies for Compliance and Risk Mitigation]
UFLPA Enforcement Actions Are Growing
A notable uptick in enforcement by U.S. Customs and Border Protection (CBP) demonstrates the breadth of the UFLPA’s implementation. A few recent examples:
- The U.S. government added 38 companies to the UFLPA Entity List in fiscal 2024, then added 29 more in late November, bringing the total to 107 targeted entities.
- The total value of shipments detained by U.S. Customs rose by 23% in fiscal year 2024.
- In the last year, three new items were named high-priority sectors for enforcement: polyvinyl chloride, aluminum, and seafood.
- In the automotive sector, the value of detained shipments in fiscal 2024 grew more than 600% over the prior year.
“CBP has been publishing detailed statistics, and we see a consistent rise in enforcement actions in key industries,” says Manon Scales, Partner at Sullivan & Cromwell, an international law firm that specializes in trade regulation. “The increase in automotive detentions is particularly telling, given the sector’s supply chain complexities.”
Looking Ahead: UFLPA Enforcement Under a New Administration
As the U.S. political landscape evolves, so too will UFLPA enforcement. Experts believe a renewed focus on China trade practices in the new presidential administration may strengthen the law’s application.
“A Trump administration, with figures like Marco Rubio in leadership, would likely ramp up enforcement, particularly in sectors viewed as strategic to U.S.-China competition,” says Adam Szubin, Counsel in Sullivan & Cromwell’s national security practice. He adds that Rubio was one of the most active senators in getting the UFLPA passed.
Experts suggest that businesses should prepare for intensified checks, more CBP agents inspecting shipments, and a tighter focus on supply chain transparency.
Why a Risk-Based, Proactive Approach Is Essential
As the number of suppliers on the UFLPA Entity List grows, many of those targeted companies are using obfuscation tactics to evade detection, like enlisting intermediaries in other countries for manufacturing and exporting. This adds complexity for companies looking to comply with the law, so experts recommend a proactive, risk-based approach to compliance.
“Rolling the dice with a wait-and-see approach can backfire,” says Jason Clark, Global Vice President of Manufacturing at Exiger. “If you’re caught and a shipment is detained, you have a 30-day window to collect all the evidence requiring item-level provenance of all the inputs of that shipment — all the way down to raw materials. And that can be a very onerous requirement.”
He recommends that a compliance program should incorporate:
- Supply chain mapping: Illuminating multi-tier networks with AI-driven technology.
- Due diligence: Screening suppliers against structured data (like the UFLPA Entity List) and unstructured sources, including adverse media in multiple languages.
- Collaboration: Engaging stakeholders at all supply chain levels to ensure transparency and auditability.
- Evidence collection: Maintaining comprehensive, item-level documentation to meet CBP’s standards.
The collaboration component is key, especially in multi-tier supply chains with hundreds or thousands of suppliers. “You need to have a way to be able to efficiently orchestrate communication and collect evidence to be able to provide that chain of evidence for the enforcement agency should they request it,” says Clark.
Advanced Technology for UFLPA Compliance and Resilience
The AI technology in the 1Exiger platform is uniquely positioned to help companies navigate UFLPA challenges. By leveraging advanced technology and deep expertise, Exiger’s solution helps you:
- Map and analyze supply chains with precision, filtering out noise to identify critical risks. This includes entity- and item-level mapping with validation of bills of materials (BOMs).
- Screen against modern slavery indicators across 96 languages, going beyond watchlists to uncover hidden risks. Exiger has the largest UFLPA dataset in the world, with a watchlist of over 3,500 entities with connections to forced labor.
- Automate supplier engagement and evidence collection, minimizing disruptions while maintaining a defensible audit trail so that you can validate the findings.
The diagram below illustrates how Exiger’s supply chain mapping technology is done at scale. The process includes screening over 50 million legal entities and 800 million locations to help pinpoint definitive chain of custody and provenance all the way down to raw materials.
Exiger’s Proactive Intelligence serves as an advanced overlay on 1Exiger’s capabilities. This tool gives you a real-time operational control experience to see how different events will impact your operations, allowing you to make quick, informed decisions.
The benefits of this comprehensive supply chain risk management approach extend beyond UFLPA compliance to making strategic decisions that deliver cost savings and operational efficiency.
“This is about doing the right thing — not only for compliance but for the broader benefits of supply chain resilience and ethical practices,” says Erika Peters, Global Head of Innovation and Operations at Exiger. “With Exiger’s solutions, companies can move from reactive firefighting to proactive, strategic compliance.”
[WATCH ON-DEMAND: Navigating UFLPA Enforcement: Strategies for Compliance and Risk Mitigation]
The UFLPA represents a major shift in how businesses must manage their global supply chains. As enforcement intensifies, the stakes grow higher. However, with a risk-based, proactive approach and the right tools, companies can navigate these challenges effectively.
Stay ahead of compliance demands and safeguard your supply chain. Contact us to partner with Exiger today to build resilience amid evolving UFLPA enforcement.
Exiger is proud to be the sole supply chain provider in the Global Data Partnership Against Forced Labor. Our commitment to ending forced labor includes partnerships with Hope for Justice, the Slave-Free Alliance, and the Anti-Slavery Collective.
