U.S. responsibility for forced labor in Xinjiang is shifting from diplomatic statements and annual human rights reports to specific trade blockades.

The U.S. government added 43 Chinese enterprises to the Uighur Forced Labour Prevention Act (UFLPA) entity list at the end of July. According to the law, as long as the goods come from Xinjiang or partly, or are produced by the listed enterprises, U.S. Customs in principle assumes that the goods involved forced labor, must not enter the U.S. market unless the importer can provide sufficient evidence to overthrow this assumption. The U.S. Department of Homeland Security forced labor enforcement teamins this list, and the U.S. Customs and Border Protection is responsible for measures such as detention, exclusion and confiscation at the port.

The addition of 43 enterprises put the Xinjiang human rights dispute back directly into the export chain of Chinese enterprises.Reuters on August 1 that the Chinese Ministry of Commerce subsequently publicly opposed U.S. measures, denied the existence of forced labor in Xinjiang, and called the new list "economic coercion" implemented under the pretext of human rights.

新疆棉供应链遭美封锁
新疆棉供应链遭美封锁

But from the U.S. legal structure, the UFLPA does not affect more than 43 companies themselves.

The law established a “refutable presumption”: as long as the supply chain touches Xinjiang or listed companies, the responsibility for proof is no longer primarily on the U.S. government, but transferred to the importer. Enterprises must prove that the relevant goods do not use forced labour in order to struggle to enter the U.S. market. For raw materials, parts, processing and final assembly of goods across multiple suppliers, this means that enterprises need to track the entire supply chain, not just prove that the final exporter is outside Xinjiang.

This mechanism directly hit the parts of the Xinjiang industrial chain that are most difficult to investigate externally.

The Chinese government has long restricted the freedom of independent journalists, human rights agencies and researchers to investigate labor conditions in Xinjiang. Even if companies claim that there is no forced labor in the supply chain, they face questions about how to demonstrate that workers can freely refuse to work, freely leave the job, and whether the transfer of labor is really on their own will. The U.S. policy thus bypasses a traditional problem: it does not require customs to first enter the Xinjiang factory to prove that every worker is forced, but rather demands that importers prove their supply chain is clean enough.

The scope of U.S. enforcement of Xinjiang goods has also been expanding in recent years.In 2025, the U.S. Forced Labour Enforcement Working Group included industries such as steel, copper, lithium, chlorine and chlorine in new key enforcement areas; the UFLPA strategy released that year shows that the list of entities has expanded from the initial 20 entities in 2022 to 144 Chinese entities.

43 companies were added to the list at the same time, meaning that the model is still expanding.

This is not a traditional way to freeze assets or ban U.S. enterprises from investing, but it adopts another way of pressure: the listed enterprises lose their proper qualification to enter the U.S. market and force international enterprises with supply relationships to re-evaluate purchasing risks.

This policy also transmits human rights responsibilities further to multinationals.

Even if a European brand does not have a factory directly in Xinjiang, its Chinese suppliers may also be subject to censorship when the relevant goods enter the United States if they use the raw materials manufactured by the list companies.

Beijing’s reaction also shows that the measure affects real economic benefits.

On August 5, the Chinese Ministry of Commerce announced countermeasures against six U.S. entities, and clearly listed these agencies as one of the grounds for "assisting and supporting U.S. sanctions involving Xinjiang."The Chinese measures show that Xinjiang's forced labor dispute has formed a clear sanctions and countermeasures chain: the U.S. blocked allegedly forced labor companies from the market, while Beijing used the Anti-Foreign Sanctions Law system to retaliate against U.S. agencies involved in relevant policies.

The Xinjiang issue is no longer just a human rights debate at the UN conference.

On the one hand, Beijing insisted on denying the systematic allegations of forced labor and described the policy as employment, poverty alleviation and career development; on the other hand, the United States under the UFLPA directly converted supply chain risks into customs embargo mechanisms.

For the Communist Party of China, this form of persecution is more difficult to avoid than a new international human rights report.

Reports can be criticized, diplomatic statements can be refuted, but whether a batch of goods can enter the U.S. market is ultimately decided by the customs.

The issue of forced labor in Xinjiang has thus entered a new phase: China’s human rights policies have begun to generate calculable international business costs.

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