The largest UFLPA expansion yet reaches aluminium and copper

On 31 July the US Department of Homeland Security added 43 companies to the Uyghur Forced Labor Prevention Act Entity List, effective 3 August. It was the largest single addition since the list began, and it took the total to 187 entities.

The products named matter more than the count. Alongside cotton, apparel and tomatoes, the additions cover aluminium and copper. Those are not textile risks. They are the metals inside transformers, switchgear, cable and busbar, which is to say inside every data-centre build and grid connection now under way.

Location matters too. Most of the new names are in Xinjiang, but several are based elsewhere in China, including Shandong, Jiangsu and Henan. A buyer who screens only for Xinjiang addresses will miss them.

Why it reaches UK and European suppliers

The UFLPA presumes that goods made wholly or partly by a listed entity, or in Xinjiang, are made with forced labour. US Customs can detain them at the border, and the importer has to rebut the presumption with evidence. A UK manufacturer that sells finished equipment into the US is exposed if any input, at any tier, traces back to a listed company.

The European Union’s own forced labour ban applies from December 2027. Buyers are already asking for the same evidence now, so that they are not caught when it does.

What a buyer will ask for

• Where the aluminium and copper in your product were smelted and refined, by name.
• Whether any supplier, at any tier, is on the Entity List or owned by an entity that is.
• Documents that trace the metal from smelter to your factory, not a declaration that it is “conflict-free”.

A supplier code that says “we do not use forced labour” does not answer any of these. Evidence of origin does.

What to do now

1. Map the metals. List every product that contains aluminium or copper, and the supplier of each.
2. Screen the chain, not just the counterparty. Check direct suppliers and their owners against the current Entity List, then ask for smelter names.
3. Close the gaps in writing. Where a supplier cannot name a smelter, record the request and the answer. A documented gap is defensible; an unasked question is not.

The list will keep growing. The cost of answering these questions rises sharply once goods are detained, so the time to collect the evidence is before the next shipment.