On January 14, 2025, the Department of Homeland Security (DHS), on behalf of the interagency Forced Labor Enforcement Task Force (FLETF), added 37 new China-based energy and textile companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of listed entities to 144. The new additions represent the single largest expansion of the UFLPA Entity List since its creation. In its press release, DHS described this large-scale addition as a sign of "the growing sophistication and maturity of the FLETF's work." Effective January 15, 2025, Customs and Border Protection (CBP) is applying a rebuttable presumption that goods produced by the named 37 entities are made with forced labor and are therefore prohibited from entering the U.S.
According to the announcement by DHS, the entities added "include globally recognized companies that mine and process Xinjiang's critical minerals, that grow Xinjiang cotton and manufacture textiles for global export, and that manufacture inputs for solar modules with polysilicon made in Xinjiang [(XUAR)]." Here are the new entities and FLETF's reason for the listing.
| Entity |
Industry |
Location |
Reason for Listing |
UFLPA Legal Auhthority |
| Donghai JA Solar Technology Co., Ltd. |
Researches and develops solar energy products and produces silicon rods, wafers, ingots, and solar cell modules. |
Jiangsu Province, China |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
| Hongyuan Green Energy Co., Ltd. (also known as HY Solar; and Hoyuan Green Energy Co. Ltd., and formerly known as Wuxi Shangji CNC Co., Ltd.; Wuxi Shangji Automation Co., Ltd.; and Wuxi Shangji Grinding Machine Co., Ltd.) |
Includes business segments involved in high-end equipment manufacturing, new energy power stations, and the production of industrial and crystalline silicon, silicon wafers, batteries, and modules. |
Jiangsu Province, China |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
| Hongyuan New Materials (Baotou) Co., Ltd. |
Produces photovoltaic monocrystalline silicon. |
Baotou City, Inner Mongolia Autonomous Region of China |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
|
Huafu Fashion Co., Ltd. (Huafu)1 and 25 Huafu subsidiaries:
- Ningbo Huafu Donghao Industrial Co., Ltd.
- Ninghai Huafu Textile Co., Ltd.
- Zhejiang Weixin Trading Co., Ltd.
- Aksu Huafu Color Spinning Co., Ltd. (also known as: Aksu Huafu Textiles Co., Ltd. Akesu Huafu, Aksu Huafu Dyed Melange Yarn, and Akesu Huafu Melange Yarn Co., Ltd.)
- Aksu Biaoxin Fiber Co., Ltd. (formerly known as Aksu Shangheng Fiber Co., Ltd.)
- Xinjiang Huafu Textile Co., Ltd.
- Xinjiang Huafu Hengfeng Cotton Industry Co., Ltd.
- Kuche Zongheng Cotton Industry Co., Ltd.
- Xinjiang Huafu Hongfeng Agricultural Development Co., Ltd.
- Shaya Yinhua Cotton Industry Co., Ltd.
- Awati Huafu Textile Co., Ltd.
- Xinjiang Huafu Color Spinning Group Co., Ltd.
- Xinjiang Huafu Cotton Industry Group Co., Ltd.
- Shihezi Standard Fiber Co., Ltd.
- Shihezi Huafu Hongfeng Cotton Industry Co., Ltd.
- Shihezi Huafu Hongsheng Cotton Industry Co., Ltd.
- Xinjiang Tianhong Xinba Cotton Industry Co., Ltd. (also known as Xinjiang Tianhong New Eight Cotton Industry Co., Ltd.)
- Huyanghe Huafu Hongsheng Cotton Industry Co., Ltd.
- Xinjiang Liufu Textile Industrial Park Co., Ltd.
- Kuitun Jinfu Textile Co., Ltd.
- Xinjiang Tianfu Cotton Supply Chain Co., Ltd.
- Xinjiang Cotton Industry Group Yuepu Lake Cotton Industry Co., Ltd.
- Xinjiang Cotton Industry Group Jiashi Cotton Industry Co., Ltd.
- Xinjiang Zefu Cotton Co., Ltd.
- Xinjiang Shengfu Cotton Industry Co., Ltd.
|
Produces and sells cotton and cotton products, with vertical integration from cotton planting, processing, yarn spinning, and textiles manufacturing. |
XUAR (22)
Ningbo City, Zhejiang Province (3)
|
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
| Jiangsu Meike Solar Technology Co., Ltd. |
Manufactures silicon rods and wafers. |
Jiangsu Province, China |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
| Baotou Meike Silicon Energy Co., Ltd. |
Manufactures silicon rods and wafers. |
Baotou City, Inner Mongolia Autonomous Region of China |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
| Shuangliang Silicon Materials (Batou) Co., Ltd. |
Researches, develops, processes, manufactures, and sells single crystal silicon rods and wafers. |
Baotou City, Inner Mongolia Autonomous Region of China |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
| Xinjiang Energy (Group) Co., Ltd. |
Wholly state-owned enterprise that develops and utilizes coal, wind, photovoltaic, oil and gas, and other resources. |
XUAR |
Reasonable cause to believe that the entity works with the government of the XUAR to recruit, transport, transfer, harbor, or receive Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the XUAR. |
Section 2(d)(2)(B)(ii) |
| Xinjiang Energy (Group) Real Estate Co., Ltd. |
Real estate development and property management. |
XUAR |
Reasonable cause to believe that the entity works with the government of the XUAR to recruit, transport, transfer, harbor, or receive Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the XUAR. |
Section 2(d)(2)(B)(ii) |
| Xinjiang Zijin Zinc Industry Co., Ltd. |
Mines and produces zinc. |
XUAR |
Reasonable cause to believe that the entity works with the government of the XUAR to recruit, transport, transfer, harbor, or receive Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the XUAR. |
Section 2(d)(2)(B)(ii) |
| Xinjiang Jinbao Mining Co., Ltd. |
Mines iron. |
XUAR |
Reasonable cause to believe that the entity works with the government of the XUAR to recruit, transport, transfer, harbor, or receive Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the XUAR. |
Section 2(d)(2)(B)(ii) |
| Zijin Mining Group Co., Ltd. (Zijin Mining)2 |
Engages in exploration and extraction of metals, including zinc, copper, lead, silver, gold, iron ore, and sulfuric acid. |
Fujian Province, China |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
| Xinjiang Zijin Zinc Industry Co., Ltd. |
Mines and produces zinc. |
XUAR |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
| Xinjiang Zijin Nonferrous Metals Co., Ltd. |
Smelts and produces refined zinc and sulfuric acid. |
XUAR |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
| Xinjiang Habahe Ashele Copper Co., Ltd.3 |
Mines and produces copper, zinc, and silver. |
XUAR |
Reasonable cause to believe that the entity sources material from XUAR. |
Section 2(d)(2)(B)(v) |
These additions reflect continued emphasis on the textile, solar, and critical mineral industries, which has rippling impacts on other industries as well. For example, the automotive industry relies heavily on textile manufacturers to provide vehicle upholstery as well as mineral producers, which provide necessary raw materials such as aluminum, zinc, iron, gold, and copper for automotive components. The addition of Zijin Mining, which is a Fortune Global 500 Company, and its subsidiary mining and smelting entities could have a significant impact on the automotive market. Zijin Mining is among the top 20 refiners of copper worldwide, holds 75 percent of China's domestic copper reserves, and is one of the largest gold, copper, and zinc producers in China. China is the world's third largest producer of copper, and on average, an internal combustion engine vehicle contains approximately 50 pounds of copper and an electric vehicle contains approximately 150 pounds of copper.
The expansion of the Entity List was announced concurrently with the publication of our firm's "UFLPA Enforcement 2024 Year in Review," in which we noted that UFLPA enforcement, including through UFLPA Entity List additions, would likely continue in 2025. Regarding the new additions, Acting Under Secretary for Policy Robert Paschall explained that "[w]ith each addition to the UFLPA Entity List, we are building momentum and showing that our efforts are sustainable and enduring in eradicating forced labor in our nation's supply chains." It appears that the 2024 enforcement trajectory is holding true for what we can expect in 2025.
For more information, please contact:
Richard A. Mojica, rmojica@milchev.com, 202-626-1571
Daniel A. Solomon, dsolomon@milchev.com, 202-626-5982
Brittany Huamani, bhuamani@milchev.com, 202-626-5911
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1Huafu was previously included in Sheffield Hallam University's (SHU) Laundering Cotton report.
2The House Select Committee on the Chinese Communist Party’s letter to Secretary Mayorkas dated January 19, 2024 asked the Department of Homeland Security to assess whether Zijin Mining, among other entities, has been involved in using Uyghur forced labor and meets the criteria for being placed on the UFLPA Entity List. Zijin Mining was also previously included in SHU's Driving Force report.
3Xinjiang Habahe Ashele Copper Co., Ltd. (also known as Ashele Copper) is already designated under Section 2(d)(2)(B)(ii) of the UFLPA Entity List and will remain listed under that sub-section as well. Section 2(d)(2)(B)(ii) covers entities believed to be engaged with the government of the XUAR to recruit, transport, transfer, harbor, or receive Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the XUAR.
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