A UFLPA detention: the 30-day clock, the two reviews, and which other entries share the risk

What does a UFLPA detention mean?

Section 3 of the Uyghur Forced Labor Prevention Act, signed on December 23, 2021, tells the CBP Commissioner to presume that goods mined, produced or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or produced by an entity on the lists the Act requires, are prohibited under 19 U.S.C. 1307 and not entitled to entry. Section 3(e) made the presumption effective 180 days after enactment, and CBP's UFLPA FAQ gives the start date as goods imported on or after June 21, 2022. Section 1307 itself bars goods made wholly or in part by forced, convict or indentured labor, including forced child labor.

The lists are combined in the UFLPA Entity List, which the Forced Labor Enforcement Task Force publishes on the DHS website. Each entity carries its own effective date, the earliest June 21, 2022, so the list on the date of entry is the one that counts. The Act requires the enforcement strategy's list of high-priority sectors to include cotton, tomatoes and polysilicon (section 2(d)(2)(B)(viii)). The Forced Labor Enforcement Task Force has widened it since. Its strategy of June 17, 2022 named apparel, cotton and cotton products, silica-based products including polysilicon, and tomatoes and downstream products; its July 9, 2024 update added aluminum, polyvinyl chloride and seafood; and its August 19, 2025 update added caustic soda, copper, jujubes (red dates), lithium and steel. Those are the strategy updates DHS lists as of November 10, 2026. CBP's guidance gives sector-by-sector tracing documentation for all twelve in its Appendix A.

A UFLPA detention is an admissibility decision, not a duty. No rate is charged on the goods because of the UFLPA; the question is whether they can enter at all. Duty measures aimed at forced labor are a separate matter and are not covered on this page.

CBP's guidance (CBP Publication 5560-0526, the version CBP posted on its website on June 12, 2026), which supersedes its June 13, 2022 UFLPA guidance, sorts shipments into two paths:

• Potential input: information indicates the goods may contain an input from Xinjiang or a listed entity. CBP detains them and the importer can respond.
• Direct input: information indicates the goods do contain such an input. CBP excludes them straight away, and the response starts at the exclusion.

What is the clock after a detention notice?

CBP detains UFLPA shipments under its ordinary examination authority, 19 U.S.C. 1499 and 19 CFR 151.16, according to its FAQ. The clocks do not all start on the same day, which is the point most often missed. Grouped by the day each one counts from:

Two costs run from day one. CBP's guidance makes the importer responsible for storage throughout any review, and says CBP may require a single transaction bond of three times the value of the detained goods when forced labor is suspected. Plan for both in the decision on whether to fight for a shipment or export it.

The notice itself must give the date the goods were presented for examination, the reason for the detention, the expected length, the tests or inquiries planned, and what information would speed things up (151.16(c)). Write the presentation date down. Because CBP has up to five business days to decide and five more to send the notice, part of the first 30 days can be gone before the notice reaches you; ask for an extension early rather than on day 29.

Which route out fits your shipment?

There are four ways a detained shipment leaves CBP's hands, and the choice depends on what your supply chain records can prove.

Most importers who contest a detention ask for an applicability review. CBP's guidance says the package should document the order, purchase, manufacture and transport of every input, and its sample list includes invoices, purchase orders, production contracts, work orders, bills of lading, foreign customs clearance, transportation records, manifests, proof of payment and certificates of origin, with an executive summary. It says affidavits, redacted documents and untranslated documents are not sufficient on their own. CBP's FAQ adds that laboratory tests, such as isotopic testing of cotton, are considered as part of the package, from samples taken under a manipulation request with a secure chain of custody.

The exception is a much harder standard. The Act requires clear and convincing evidence, which CBP's FAQ describes as a higher standard than a preponderance of the evidence. Each exception CBP grants is reported to Congress within 30 days, identifying the good and the evidence considered (UFLPA section 3(c)).

Which past and pending entries share the risk?

A detention tells you CBP has information linking a supplier, a producer or an input to Xinjiang or a listed entity. That information does not stop at one container. The days after the notice are the time to find every other entry that rests on the same facts, using your own entry export.

1. Match on the manufacturer. Pull every entry line with the same manufacturer identification code in block 13 of the entry summary, and the same manufacturer name and address under other codes. CBP's FAQ says that since March 18, 2023 ACE requires a valid Chinese postal code for the manufacturer on cargo release when the country is China, and warns when the code is in Xinjiang, so the postal codes on your own filings are a first screen.
2. Match on the supplier and the inputs. Add entries from the same seller or trading company, and entries of other finished goods that use the same raw material or component from the same upstream producer. The detention package you are building lists those producers; reuse it as the search list.
3. Match on HTS lines in the priority sectors. Flag every line in the sectors the Act and CBP's guidance name, from any supplier, where the upstream producers have not been traced.
4. Check the Entity List by date. For each upstream producer, check the DHS list and the effective date of any listing against the dates of your entries.
5. Sort the matches by status:

CBP's FAQ says that when a shipment comes from a supply chain identical to one CBP has already reviewed and cleared, a summary tracing report with the producers for every stage and a business record for each has brought average detentions down to 10 to 14 days. So a cleared package is worth keeping and indexing by supplier, for every future shipment.

If the search finds forced-labor inputs in goods already entered, CBP's guidance points to a prior disclosure made to the Center for your industry or to the Forced Labor Division before CBP discovers the issue. That is a filing for trade counsel. This page describes the procedure and is not legal advice.

What does the review package look like in practice?

CBP's best-practice material, summarized in its FAQ, comes down to preparation before any detention:

1. Have a response plan, with suppliers who know the UFLPA and documents ready to send.
2. Agree how suppliers will share sensitive records. CBP's FAQ says a seller or exporter can send documents directly to CBP, provided the importer is told.
3. Talk to the Center early about high-risk imports, before they arrive.
4. Send a complete, organized package with English translations, and a supplier list that shows each supplier's role in production.
5. Answer CBP's follow-up questions quickly and fully. For an exception, completeness is a legal condition, not a courtesy (UFLPA section 3(b)(1)(B)).

Where does TariffSense fit?

The search in the previous section runs on entry data you already hold: manufacturer, supplier, origin, HTS number, entry date and status on every line. TariffSense reads Form 7501s and broker entry exports in any layout into those fields, and the post-entry audit page shows what comes back. The tracing evidence, and every decision on the detention, stays with your compliance team, your broker and counsel.

What should you do next on your own entries?

Before any detention, list your top suppliers of goods in the priority sectors and write down, for each, the producer at every stage back to the raw material, with one business record per stage. Where you cannot fill a stage in, that is the supply chain most likely to be detained and least ready to be released. The country of origin guide covers how origin is decided for other purposes, how to file a customs protest covers the protest after an exclusion, and the post-entry audit pillar covers the rest of the line checks.