UFLPA 2025 Compliance Checklist for Amazon & Shopify Sellers How to Keep U.S. Imports Admissible and Out of CBP Detention

TL;DR
The Uyghur Forced Labor Prevention Act (UFLPA) has moved from a “China cotton issue” to a broad supply-chain enforcement regime. As of January 15, 2025, the DHS UFLPA Entity List includes 144 entities, and CBP has detained more than 6,000 shipments worth billions of dollars, including many small-parcel e-commerce imports. De minimis (under $800) shipments are no longer a safe loophole. Amazon FBA and Shopify brands importing into the U.S. must be able to prove, with clear and convincing evidence, that their goods are free of Xinjiang (XUAR) links and free of any entities on the UFLPA list. This guide gives you a practical, 4-phase checklist to build a defensible UFLPA compliance program, prepare a complete CBP rebuttal package, and keep your products out of detention.

QUICK ACTION GUIDE — WHAT TO DO THIS QUARTER

If you are an Amazon or Shopify seller already shipping to the U.S., use this quick sequence as your “UFLPA action plan.”

• Step 1 – Name an owner: Assign a single UFLPA compliance owner (often the import compliance manager or head of operations).
• Step 2 – Issue a zero-tolerance policy: Publish an internal forced-labor and UFLPA policy, and push it to all suppliers.
• Step 3 – Map high-risk SKUs: Identify products in textiles, solar, electronics, EV batteries, metals, PVC, aluminum, and red dates as priority.
• Step 4 – Trace back to raw materials: For each high-risk SKU, build a documented chain from raw material to finished good.
• Step 5 – Screen against the UFLPA Entity List: Verify that no factory, trader, or upstream processor is on the DHS list (144 entities as of Jan 2025).
• Step 6 – Build your CBP rebuttal package template: Prepare a standard document pack with invoices, production records, utility bills, payroll, and audit reports.
• Step 7 – Align Amazon FBA / Shopify SFN flows: Ensure your 3PL and FBA/SFN routing are traceable and consistent with your documentation.
• Step 8 – Run a tabletop detention drill: Simulate a CBP detention and rehearse a 30-day rebuttal response.

If you need help benchmarking your current risk or tracing a specific SKU, you can work with the WinsBS U.S. fulfillment & import compliance team or request a free diagnostic below.

INTRODUCTION — WHY UFLPA NOW DEFINES E-COMMERCE IMPORT RISK

The Uyghur Forced Labor Prevention Act (UFLPA) has been in force since June 2022. It flips the burden of proof: any goods wholly or partly mined, produced, or manufactured in China’s Xinjiang Uyghur Autonomous Region (XUAR), or involving entities on the UFLPA Entity List, are presumed to be made with forced labor and therefore inadmissible into the United States.

As of the January 15, 2025 Federal Register update, the UFLPA Entity List maintained by the U.S. Department of Homeland Security (DHS) has expanded to 144 entities, including parent companies, subsidiaries, and affiliates. Throughout 2024–2025, U.S. Customs and Border Protection (CBP) has detained more than 6,000 shipments under UFLPA, targeting not only bulk consignments but also e-commerce small parcels and de minimis shipments flowing to Amazon FBA and direct-to-consumer brands.

For Amazon and Shopify sellers, UFLPA is no longer an abstract policy issue. If you are the Importer of Record (IOR), CBP will expect you to demonstrate that your supply chain is free from forced labor and free from any UFLPA-listed entities. Even if Amazon, Shopify, or a 3PL handles your logistics, you remain responsible for admissibility.

This guide is written for U.S.-bound brands using Amazon FBA, Shopify, and third-party logistics (3PL) networks. It translates the UFLPA framework into a practical 4-phase checklist, with tables, risk matrices, and documentation examples that you can immediately align with your operations.

UFLPA IN 2025 — WHAT CHANGED AND WHY IT MATTERS

Before you build a checklist, you need a clear snapshot of the 2025 enforcement landscape.

1.1 UFLPA Entity List — 144 Entities and Growing Scrutiny

As of November 2025, following the DHS announcement on January 14, 2025 and the Federal Register notice on January 15, 2025, the UFLPA Entity List includes 144 entities. These cover a wide network of Chinese companies and affiliates involved in:

• Textiles and apparel (including cotton and yarn originating in XUAR)
• Polysilicon and solar supply chains
• Metals such as copper, aluminum, lithium-related materials, and steel inputs
• Chemicals including caustic soda used in textile and industrial processing
• Agricultural products such as red dates and other specialty crops

Any direct or indirect sourcing from entities on this list places your shipment under the UFLPA rebuttable presumption, meaning your goods are presumed inadmissible unless you can overturn that presumption.

1.2 High-Risk Sectors for E-Commerce Brands

CBP and DHS have signaled particular concern around the following sectors, which are common in Amazon and Shopify catalogs:

• Apparel & textiles: T-shirts, hoodies, activewear, socks, underwear, fashion accessories.
• Electronics & components: consumer electronics, PCBs, power banks, chargers, smart devices.
• EV and battery products: e-bikes, scooters, power tools, lithium-ion modules.
• Solar-related and metals: lighting, small solar kits, components with copper, aluminum, or steel.
• Plastic & PVC products: flooring, accessories, industrial components.
• Food & agricultural: red dates, snacks, and specialty ingredients.

1.3 The FLETF 4-Dimensional Risk Lens

The Forced Labor Enforcement Task Force (FLETF) focuses on four dimensions of risk:

• Geographic risk: direct or indirect links to XUAR or other high-risk locations.
• Entity risk: relationships with companies on the UFLPA Entity List or their affiliates.
• Commodity risk: categories like cotton, polysilicon, lithium, aluminum, PVC, and seafood.
• Supply-chain risk: opacity, intermediaries, and missing documentation across tiers.

Your compliance program should mirror this lens: not just “China vs. non-China,” but a structured evaluation across geography, entities, commodities, and supply-chain transparency.

PHASE 1 — BUILD AN INTERNAL UFLPA COMPLIANCE PROGRAM

UFLPA compliance starts inside your organization. CBP will look for a credible, documented program, not just a one-off supplier questionnaire.

2.1 Policy, Governance, and Training

At a minimum, Amazon and Shopify brands should implement the following policy-level actions:

If you do not yet have an internal import compliance function, you can rely on external advisors or a 3PL partner. WinsBS, for example, supports U.S.-bound brands with combined fulfillment + UFLPA risk review through its U.S. fulfillment network.

PHASE 2 — MAP, TRACE, AND RANK YOUR SUPPLY-CHAIN RISK

UFLPA requires “reasonable care” and “reasonable due diligence” with a clear focus on upstream tiers. For e-commerce brands, that means tracing your supply chain from raw materials to finished goods, not just your Tier-1 assembler.

3.1 Supply Chain Tracing Flow — From Raw Material to FBA Bin

Use this simplified flow as a template to document each high-risk product line:

3.2 Supplier Due-Diligence Questionnaire (Practical Template)

For high-risk SKUs, require upstream suppliers to complete a structured questionnaire. At a minimum, include:

• Full legal name, address, and ownership structure for all factories involved in production.
• Disclosure of any operations, affiliates, or subcontractors in XUAR or adjacent high-risk regions.
• Confirmation that no entity on the UFLPA Entity List participates in mining, processing, manufacturing, or logistics.
• Ability and willingness to provide unredacted payroll records, utility bills, production logs, and worker rosters for audits.
• Details of any government-supported “labor transfer programs” or other arrangements involving worker placement.
• History of social compliance audits (names of auditors, findings, corrective action plans).

This questionnaire should be backed by contractual language allowing you or your auditors to verify responses through site visits, remote audits, and document review.

3.3 UFLPA Risk Matrix — Prioritizing What to Fix First

Use a simple risk matrix to prioritize investigation and documentation:

High-risk combinations should be prioritized for immediate remediation, supplier changes, or deeper audit work.

If you are unsure which SKUs would be detained first under UFLPA, WinsBS can run a rapid supply-chain mapping exercise across your Amazon and Shopify catalog. Within one business day, you will receive a risk-ranked view of products, suppliers, and documentation gaps. Request a free UFLPA risk scan (5-second form) .

PHASE 3 — BUILD A DEFENSIBLE CBP DOCUMENTATION & REBUTTAL PACKAGE

CBP expects importers to be ready with a comprehensive documentation file before detention happens. The core concept is simple: you must provide clear and convincing evidence that your goods are not made with forced labor and are not linked to XUAR or UFLPA-listed entities.

4.1 The Three Core Elements of a UFLPA Rebuttal Package

4.2 What CBP Does Not Accept (The “No-List”)

Many rebuttal packages fail because they rely on weak or incomplete evidence. Common pitfalls include:

• Redacted documents: CBP has repeatedly stressed that heavily redacted payrolls, utility bills, and invoices are not acceptable.
• Generic letters of assurance: One-page statements such as “we do not use forced labor” without supporting documentation carry little weight.
• Unverifiable or inconsistent invoices: Mismatched quantities, dates, or HS codes create doubt about traceability.
• Audits with no worker-level evidence: Checklists without worker interviews, payroll testing, or shift data are insufficient.
• Documents in name only: Files that exist on paper but cannot be tied to specific SKUs, POs, or shipments.

4.3 Practical Documentation Checklist for CBP

For each high-risk shipment or SKU, assemble and archive the following categories of records:

4.4 30-Day Detention Roadmap — How to Respond Under Pressure

When CBP detains a shipment, the clock starts immediately. A simple roadmap:

• Day 0–3: Confirm detention notice details, SKUs involved, and CBP’s stated concerns. Freeze related shipments.
• Day 3–7: Pull your pre-built documentation pack for the affected suppliers and SKUs; identify any gaps.
• Day 7–20: Work with suppliers, auditors, and legal counsel to fill documentation gaps and prepare an organized rebuttal file.
• Day 20–25: Finalize the executive summary, table of contents, and evidence index for CBP reviewers.
• By Day 30: Submit the rebuttal package, keeping a complete internal archive for future audits.

PHASE 4 — ALIGN AMAZON FBA & SHOPIFY SUPPLY CHAINS WITH UFLPA

Amazon and Shopify do not provide UFLPA-specific “safe harbor” pages. Their policies are clear: you are responsible for complying with U.S. law. However, the way products move through FBA, SFN, and 3PL networks can either strengthen or weaken your UFLPA posture.

5.1 Amazon FBA — Commingling, FC Transfers, and Documentation

For Amazon sellers, UFLPA risk is compounded by operational realities:

• Commingled inventory: Where Amazon pools physical units from multiple sellers, tracing a detained batch becomes harder.
• FC transfers: Goods may move between fulfillment centers without your direct control, making documentation alignment critical.
• Global Logistics & de minimis: FBA inbound via small parcels still falls under UFLPA scrutiny; de minimis is not a shield.

5.2 Shopify & SFN — Cross-Border and Drop-Ship Risks

Shopify brands face a different set of UFLPA challenges:

• Drop-shipping from China: Many Shopify stores rely on suppliers they have never visited, with no upstream visibility.
• Markets Pro & cross-border tools: Automated duty and tax calculations do not replace UFLPA due diligence.
• Multi-node fulfillment: Using multiple 3PLs can fragment your documentation if not centrally managed.

CASE STUDY — WHEN ELECTRONICS INVENTORY GOT DETAINED

OUTLOOK 2025–2026 — WHAT AMAZON & SHOPIFY SELLERS SHOULD EXPECT

If you operate an Amazon or Shopify brand and are unsure whether your products could be detained under UFLPA, consider running a focused supply-chain review across your top SKUs, suppliers, and warehouses. WinsBS combines U.S. order fulfillment with import-compliance support, helping brands redesign their logistics so that inventory can move faster while staying within U.S. law. Start with a free UFLPA supply-chain screening .

FAQ — COMMON QUESTIONS FROM AMAZON & SHOPIFY SELLERS

1. Can Amazon FBA inventory be detained under UFLPA?

Yes. CBP can detain FBA inbound shipments just like any other import. If your products or suppliers are linked to XUAR or the UFLPA Entity List, CBP may detain your cargo before it reaches the fulfillment center. Amazon will then restrict or suspend processing until the issue is resolved.

2. Are de minimis shipments under $800 exempt from UFLPA?

No. De minimis shipments are still subject to UFLPA. CBP is increasingly interested in small-parcel flows used by cross-border e-commerce brands. You should maintain the same level of supply-chain documentation for de minimis parcels as for regular entries.

3. What documents does CBP expect in a UFLPA rebuttal package?

CBP expects detailed supply-chain tracing, mapping, and risk-mitigation evidence. That typically includes BOMs, invoices, production records, payroll and timekeeping data, utility bills, worker rosters, and social compliance audits for all relevant tiers. Generic assurance letters are not enough.

4. Does using a 3PL or SFN shift UFLPA responsibility away from my brand?

No. While 3PLs and SFN providers can help organize documentation and respond to CBP, the importer of record remains responsible under U.S. law. You should build UFLPA obligations into your contracts and ensure your fulfillment partners can support your evidence needs.

5. How often should I review my suppliers for UFLPA risk?

At minimum, review high-risk suppliers annually and whenever DHS updates the UFLPA Entity List. For critical SKUs in apparel, electronics, batteries, and metals, quarterly monitoring is advisable, especially if you rely heavily on Chinese sourcing.