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Forced labour import bans: US UFLPA, EU Regulation 2024/3015 and Canada

The United States, Canada and the European Union block goods made with forced labour. In the US the Uyghur Forced Labor Prevention Act (UFLPA) presumes that goods made wholly or in part in Xinjiang, or by listed entities, are made with forced labour; the EU ban under Regulation (EU) 2024/3015 applies from 14 December 2027. Exporters, including those outside China, need to be able to trace their inputs.

Checked against official sources: 2026-10

At a glance

UFLPAEnacted 23 December 2021; the rebuttable presumption has applied since 21 June 2022
US presumptionGoods made wholly or in part in Xinjiang or by entities on the UFLPA Entity List are presumed to violate Section 307 of the Tariff Act of 1930 (19 U.S.C. 1307)
UFLPA Entity List144 entities after the 19 August 2025 strategy update, 78 of them added since 2024
US high-priority sectorsApparel, cotton, silica-based products including polysilicon, tomatoes, aluminium, PVC, seafood, caustic soda, copper, jujubes (red dates), lithium and steel
US enforcementCBP examined more than 16,000 shipments valued at almost USD 3.7 billion between June 2022 and July 2025
EU RegulationRegulation (EU) 2024/3015, in force since 13 December 2024, applies from 14 December 2027 to all products in all sectors
EU decisionsBan on placing on the market or export, withdrawal and disposal, in principle within 30 working days
CanadaSince 1 July 2020, goods produced wholly or in part by forced labour are prohibited under tariff item 9897.00.00

United States: UFLPA and Section 307

Section 307 of the Tariff Act of 1930 (19 U.S.C. 1307) already prohibited imports of goods produced by forced labour. The UFLPA, enacted on 23 December 2021, added a rebuttable presumption from 21 June 2022: goods mined, produced or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or by an entity on the UFLPA Entity List, are presumed to be made with forced labour and are not entitled to entry. The presumption follows inputs, so a product finished in another country can be caught if it contains cotton, polysilicon or other materials from Xinjiang.

The strategy update of 19 August 2025 added caustic soda, copper, jujubes (red dates), lithium and steel to the high-priority sectors, alongside aluminium, apparel, cotton and cotton products, PVC, seafood, silica-based products including polysilicon, and tomatoes and downstream products. The UFLPA Entity List then had 144 entities.

When CBP detains a shipment

CBP notifies the importer of the reason for detention, and the importer generally has 30 days from the date the shipment is presented for examination to respond. The importer can show that the goods have no link to Xinjiang or to a listed entity. For an exception, the importer must have complied fully with the UFLPA strategy guidance, responded completely and substantively to all CBP requests for information, and shown by clear and convincing evidence that the goods were not made wholly or in part with forced labour. An exclusion can be protested under 19 U.S.C. 1514.

EU Forced Labour Regulation from 14 December 2027

Regulation (EU) 2024/3015, published on 12 December 2024 and in force since 13 December 2024, prohibits placing or making available on the EU market, and exporting from the EU, products made with forced labour at any stage, from extraction and harvest to production and processing. It applies from 14 December 2027 to all products in all sectors. The Commission investigates suspected forced labour outside the EU and national competent authorities investigate inside the EU, using a risk-based process with a preliminary phase before any investigation.

If a violation is found, the authority can ban the product, order its withdrawal from the market and its disposal, in principle within 30 working days, and at least 10 working days for perishable goods, animals and plants. If only a replaceable part of the product is in violation, the disposal order applies only to that part. The Commission planned its guidelines and the Forced Labour Single Portal for June 2026, together with a public database of forced labour risks.

Canada

Since 1 July 2020, under the law implementing CUSMA, tariff item 9897.00.00 of the Customs Tariff prohibits goods produced wholly or in part by forced labour. When border services officers find such goods, they classify them under this item and refuse entry; importers may appeal the classification, re-export the goods or abandon them.

Step by step

  1. Map each product's supply chain back to the raw materials, especially cotton, polysilicon, aluminium, PVC, steel, copper and lithium.
  2. Check your suppliers, and their suppliers, against the UFLPA Entity List.
  3. Keep traceability records for every input: purchase orders, invoices, payment records, production records and transport documents.
  4. Put a no-forced-labour clause in supplier contracts and audit higher-risk suppliers.
  5. If a US shipment is detained, send the evidence quickly; the response window is generally 30 days.
  6. For the EU, prepare due diligence before 14 December 2027 and follow the Commission's guidelines and risk database.

Documents you usually need

Common problems and how to avoid them

A US buyer's shipment is detained under the UFLPA.

What to do: Show that the goods have no link to Xinjiang or to listed entities, or meet the exception conditions with clear and convincing evidence; respond within the deadline, generally 30 days.

A supplier cannot say where its cotton or polysilicon comes from.

What to do: Both are high-priority sectors; trace the input to its origin or change supplier.

A product sold in the EU after 14 December 2027 is linked to forced labour.

What to do: The authority can ban it and order withdrawal and disposal, in principle within 30 working days; due diligence started now reduces this risk.

Canadian customs classify goods under tariff item 9897.00.00.

What to do: The importer may appeal the classification, re-export the goods or abandon them.

Sources

  1. UFLPA annual strategy update: new high-priority sectors and 78 entities added (August 2025) Thompson Hine
  2. Trump Administration issues 2025 UFLPA strategy and related updates (September 2025) Debevoise & Plimpton
  3. CBP enforcement of the new UFLPA restrictions (July 2022) DLA Piper
  4. New regulation will ban products made with forced labour from Union market eucrim
  5. The EU Forced Labour Regulation: 10 questions every general counsel should be asking (15 June 2026) Mayer Brown
  6. Import prohibition on goods produced by forced labour Public Safety Canada

Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.

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Common questions

What is the UFLPA rebuttable presumption?

From 21 June 2022, goods made wholly or in part in Xinjiang or by entities on the UFLPA Entity List are presumed to be made with forced labour and are not entitled to entry into the United States.

Does the UFLPA apply to goods made outside China?

Yes. The presumption covers goods made wholly or in part in Xinjiang or by listed entities, so a product finished in another country can be caught through its inputs.

Which sectors does CBP prioritise?

Apparel, cotton, silica-based products including polysilicon, tomatoes, aluminium, PVC, seafood, and since August 2025 also caustic soda, copper, jujubes (red dates), lithium and steel.

When does the EU forced labour ban apply?

From 14 December 2027, under Regulation (EU) 2024/3015, to all products in all sectors, both imported and exported.

Is there a size threshold in the EU regulation?

It covers all products in all sectors; the regulation provides accompanying measures for micro, small and medium-sized enterprises.

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