UFLPA 2025 Checklist for Amazon & Shopify Sellers
UFLPA 2025 Compliance Checklist for Amazon & Shopify Sellers How to Keep U.S. Imports Admissible and Out of CBP Detention By Maxwell Anderson · WinsBS Research · Updated November 2025 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









