Forced Labor Compliance & UFLPA Enforcement Solution
Avoid the CBP hold.
Not just respond
after you get one.
UFLPA shifted the burden of proof. Now importers must demonstrate goods aren’t produced with forced labor — or face detention. Sayari maps your supply chain independently so you know your exposure before CBP does.
The law changed. The burden of proof is now on you.
The Uyghur Forced Labor Prevention Act (UFLPA), in force since June 2022, created a rebuttable presumption that any goods mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region were made with forced labor — and are therefore prohibited from entering the United States.
That means the burden of proof shifted. Previously, CBP had to prove forced labor. Now, importers must prove their goods are clean. And CBP has only gotten more aggressive: detention rates increased over 300% from Year 1 to Year 2 of enforcement.
Sayari maps the supply chain independently using 4B+ trade transactions — identifying the Xinjiang nexus at tier-2 and tier-3 before a shipment ever reaches the port.
Rebuttable presumption
Any goods with a Xinjiang connection are presumed to be made with forced labor. You must rebut this presumption with clear and convincing evidence.
30-day response window
After CBP issues a detention notice, importers have 30 days to submit rebuttal evidence. Sayari can generate the documentation needed for that response.
UFLPA Entity List
CBP maintains a list of companies specifically identified for forced labor risk. Any supply chain connection to listed entities triggers automatic review.
Sub-tier supplier exposure
The law applies to goods produced “wholly or in part” — meaning a Xinjiang cotton component in tier-3 creates full importer liability.
Forced labor exposure signals in your supply chain.
Xinjiang geographic exposure
Facilities operating in or sourcing from the XUAR — identified through trade records, company registrations, and facility databases.
UFLPA Entity List matches
Direct or indirect supplier relationships with entities CBP has specifically identified for forced labor risk — at any tier in your supply chain.
Government labor transfer programs
Facilities participating in Chinese government labor transfer programs associated with XUAR forced labor — identified through government procurement and corporate records.
High-risk commodity exposure
Cotton, polysilicon, tomatoes, steel, aluminum — commodities with documented XUAR production concentration — anywhere in your bill of materials.
Ownership by restricted parties
Suppliers owned or controlled by entities on the UFLPA Entity List, OFAC SDN, BIS Entity List, or other restricted party lists.
Adverse media and NGO reporting
Prior forced labor allegations, investigative reporting, and NGO documentation — the early warning signals before regulatory action.
Sayari helps build your rebuttal evidence in days, not weeks.
Map the detained shipment
Use Sayari to trace the full supply chain of the detained goods — identifying every supplier, facility, and ownership connection.
Identify & document the nexus
Pinpoint the specific node creating CBP concern — a Xinjiang-region supplier, an UFLPA entity match, or a labor transfer program connection.
Build rebuttal documentation
Generate source-cited evidence packages showing supply chain traceability, ownership, and absence of forced labor indicators for each node.
Submit to CBP
Submit the complete documented rebuttal package to CBP within the 30-day window — with the primary source citations they require.
Common questions about forced labor compliance
Sayari maps your supply chain from the point of import back through every tier using customs data, corporate registries, and ownership records. This reveals connections to UFLPA Entity List companies that exist below Tier 1 — in sub-suppliers, raw material sources, and intermediate processors — where most forced labor exposure actually resides.
Responding to a WRO requires demonstrating that goods are not produced with forced labor. Sayari provides source-documented evidence chains: corporate ownership records showing the actual entities involved at every tier, trade data showing the physical flow of goods, and entity resolution linking those entities to (or clearing them from) forced labor indicators — the documentation CBP expects.
The Entity List covers designated entities, but forced labor risk extends far beyond it. Sayari identifies risk indicators including Xinjiang geographic exposure, connections to companies with known forced labor findings, ownership by entities in high-risk sectors (polysilicon, cotton, tomatoes), and transshipment patterns consistent with origin-washing — providing a comprehensive view that goes beyond list-based screening.
Yes. While UFLPA focuses on Xinjiang, the EU Corporate Sustainability Due Diligence Directive and Germany’s Lieferkettensorgfaltspflichtengesetz require human rights due diligence across global supply chains. Sayari’s multi-tier supply chain mapping and continuous monitoring support these frameworks by providing the visibility and documentation required to demonstrate adequate due diligence.
Transshipment is the primary evasion tactic for forced labor restrictions — goods are routed through third countries to obscure their Xinjiang origin. Sayari detects transshipment indicators by analyzing trade flow patterns, identifying unusual routing, matching shipment volumes against production capacity, and tracing ownership connections between origin and intermediary entities.
chain mapping
the enforcement reality
builds evidence in days
Know your exposure before CBP does.
Request a demo. We’ll run Sayari’s forced labor risk screening against your key suppliers and show you what’s in your supply chain before it shows up at the port.