The Uyghur Forced Labor Prevention Act (UFLPA) creates a rebuttable presumption that 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 prohibited from entering the United States under 19 U.S.C. §1307. CBP’s UFLPA page says the presumption applies unless the importer shows, by clear and convincing evidence, that the goods were not made with forced labor. CBP has identified cotton as a high-risk commodity. This is not legal advice, and a customs broker or lawyer should review your own situation.

The Entity List keeps growing

DHS maintains the UFLPA Entity List. On 31 July 2026 it announced 43 additions, effective 3 August 2026, which brought the list to 187 entities, and said the new entries include companies in apparel and cotton among other sectors. Check your supplier and its yarn spinner, fabric mill and dye house, with any aliases and subsidiaries, against the current list on the DHS website, not a copy from an older article.

What CBP guidance describes

CBP’s operational guidance for importers lists documentation for cotton, including records that show the entire supply chain from the origin of the cotton at the bale level to the finished product. It asks for a flow chart of the production process, identification of every entity involved in each step, and business records such as purchase orders, payment records, invoices and transport documents. The lists are examples, and CBP may ask for more.

The PDF cited below is the June 2022 edition of CBP’s importer guidance. CBP’s UFLPA page lists the current guidance and a document called the UFLPA Attachment to the Notice of Detention, which gives example documents importers may consider providing to secure release of a shipment, so read both before you write your request to the factory.

Ask the factory early

Tell the factory before you place the order that you will need these records and ask who the yarn spinner, fabric mill and dye house are. A factory that cannot or will not say where its cotton yarn and fabric come from is a risk. Ask whether it can provide supplier documents with names and addresses for each step, in English where needed, and whether it keeps them for each order.

Link records to your order

General records are less useful than records that tie to your shipment: yarn and fabric lot numbers, cutting records and packing lists that match the quantities you are importing. Ask that carton and invoice quantities reconcile with the production records. Keep your own copies, since CBP can ask the importer, not the factory.

If a shipment is detained

CBP’s FAQ explains that an importer can request an applicability review and show that the goods are not sourced from the region or from listed entities, using ordinary business documents. Having the file ready saves time compared with building it after detention.

Importer responsibility

CBP’s informed-compliance material makes the importer of record responsible for reasonable care in entering and classifying goods. A factory’s assurance is not a substitute for records you can show.