Dodd-Frank Act, Section 1502 (Conflict Minerals)
Calendar year 2025 filings fell due on 1 June 2026; the regime and the SEC enforcement posture are unchanged.
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A rebuttable presumption that goods linked to Xinjiang are made with forced labour and barred from US entry.
Largest Entity List expansion to date on 31 July 2026: 43 entities added, taking the list to 187, across aluminium, apparel, copper, cotton and tomatoes.
In plain language
The UFLPA presumes that goods mined, produced or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or by entities on the UFLPA Entity List, are made with forced labour and prohibited from entering the United States. Importers can rebut the presumption only with clear and convincing evidence, which in practice demands full upstream traceability.
Enforcement has widened steadily: the Entity List has grown across aluminium, seafood, polysilicon and agricultural sectors, and detentions now routinely affect goods shipped from third countries with Xinjiang-origin inputs. On 31 July 2026 DHS announced 43 additions in a single notice, the largest expansion since the act took effect, bringing the list to 187 entities with additions in aluminium, apparel, copper, cotton and tomatoes. For South Asian exporters, proving the absence of covered inputs has become a standing documentary burden.
Obligations
Importers must be able to map inputs to origin and demonstrate no nexus to Xinjiang or listed entities.
Rebutting the presumption requires clear and convincing evidence, complete supply chain documentation and responses to CBP within strict timelines.
Timeline
Act signed into law.
Rebuttable presumption took effect and enforcement began.
Entity List expanded repeatedly and enforcement statistics broadened across sectors.
DHS announced 43 Entity List additions, the largest single expansion, taking the list to 187 entities; the notice was published in the Federal Register on 3 August 2026. CBP reported more than 24,300 shipments denied entry, valued at nearly 1 billion dollars.
Changelog
Added the July 2026 Entity List expansion to 187 entities and the latest CBP enforcement figures.
Entity List additions and sectoral detention statistics updated.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Same jurisdiction
Calendar year 2025 filings fell due on 1 June 2026; the regime and the SEC enforcement posture are unchanged.
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