Since June 2022, CBP has enforced a rebuttable presumption under the Uyghur Forced Labor Prevention Act (UFLPA): any goods with inputs traced to Xinjiang, or to any of the 144-plus entities on the UFLPA Entity List, are assumed forced-labor tainted and blocked at the border unless the importer proves otherwise with "clear and convincing evidence" — a standard courts have effectively made unbeatable. Cotton is one of the statute's six named high-priority sectors, and CBP's own dashboard shows over 16,700 shipments reviewed and nearly $3.7 billion in goods stopped, with release rates under 7%. For apparel-heavy importers like Walmart, Target, and Nike, that isn't a legal risk anymore — it's a sourcing-map problem. The money isn't made by the retailers absorbing the compliance cost. It's made by whoever gets paid to prove a garment's cotton never touched Xinjiang, and by the regions retailers are now forced to buy from instead.
Trade & Tariffs
The UFLPA Enforcement Wave: The Auditors Cash In, Not the Retailers
CBP's rebuttable-presumption crackdown on Xinjiang cotton is forcing Walmart, Target, and Nike to re-route sourcing to the Western Hemisphere and India — and to pay for proof of it.
