03 10 2024

Supporting the Chinese Uyghur Muslims by Addition of Companies to the UFLPA ( Uyghur Forced Labor Prevention Act) Entity List

Earlier in the summer, the US FLETF (Forced Labor Enforcement Task Force) added several entities to the UFLPA Entity List. On June 11, it announced the addition of three Chinese entities, representing three industry sectors: seafood, footwear, and aluminum. Specifically, the entities added in June were:

Shandong Meijia Group Co., Ltd. (aka Rizhao Meijia Group), which processes, sells, and exports frozen seafood products and vegetables, among other foodstuffs;

Dongguan Oasis Shoes Co., Ltd. (aka Dongguan Oasis Shoe Industry Co., Ltd.; Dongguan Luzhou Shoes Co., Ltd.; and Dongguan Lvzhou Shoes Co., Ltd.), which manufacturers shoes; and

Xinjiang Shenhuo Coal and Electricity Co., Ltd., which produces electrolytic aluminum, graphite carbon, and prebaked anodes.

But the FLETF was just warming up.

On August 8, 2024, it added a further five entities to the UFLPA Entity List, including three entities based in mainland China and two Hong Kong entities. Three of the five newly added entities are involved in the magnesium industry. The entities added in August include:

Xinjiang Habahe Ashele Copper Co., Ltd., which mines non-ferrous metals, including zinc, copper, and silver;

Kashgar Construction Engineering (Group) Co., Ltd., which is involved in real estate development, construction engineering and operations, general construction, and the manufacture of construction materials and components;

Century Sunshine Group Holdings, Ltd., which is based in Hong Kong and manufactures magnesium alloys and magnesium fertilizer;

Rare Earth Magnesium Technology Group Holdings, Ltd., which is based in Hong Kong and manufactures and sells magnesium alloys; and

Xinjiang Tengxiang Magnesium Products Co., Ltd., which manufactures magnesium and magnesium alloy products.

Items imported from a company on the UFLPA Entity List are presumed to be produced through forced labor and are prohibited from entering the United States pursuant to Section 307 of the Tariff Act of 1930. An importer may overcome the presumption by providing clear and convincing evidence that the goods were not produced with forced labor, which requires evidence mapping its entire supply chain.

The UFLPA Entity List now contains 73 entities, and there is certainly the potential for the list to grow further in the near future.