Forced labour: UFLPA and the Section 301 tariff
On 31 July 2026 DHS added 43 Chinese companies to the UFLPA Entity List, which DHS called the largest expansion yet, bringing the list to 187 entities from 3 August. Goods made by listed companies are presumed barred from U.S. entry (a rebuttable presumption), and CBP has denied entry to more than 24,300 shipments worth nearly $1 billion since the law took effect. Separately, the U.S. imposed Section 301 tariffs on 60 economies according to whether they ban forced-labour imports; Korean goods have faced a combined 12.5% including the MFN rate since 24 July, with Section 232 goods and some others excluded.
How it unfolded.
- 2025-08-19
DHS's 2025 UFLPA Strategy update adds caustic soda, copper, jujubes, lithium and steel as high-priority sectors, alongside aluminium, apparel, cotton, PVC, seafood, silica-based products including polysilicon, and tomatoes (12 in total). source ↗
- 2026-02-20
The U.S. Supreme Court rules IEEPA-based reciprocal tariffs unlawful; Washington turns to Sections 301 and 232, widening tariff rationales to labour, supply chains and security (National Assembly Research Service). source ↗
- 2026-03-12
USTR opens Section 301 investigations into economies that fail to ban imports of forced-labour goods (60 economies). source ↗
- 2026-06-09
CBP issues forced-labour enforcement guidance for importers: 'reasonable care' includes checking and keeping information that shows goods were not made with forced labour (Law Times). source ↗
- 2026-07-23
USTR finalises the forced-labour Section 301 tariffs: 12.5% for Korea including the MFN rate (no extra duty where MFN is already 12.5% or more), effective 24 July. source ↗
- 2026-07-31
DHS adds 43 companies to the UFLPA Entity List (effective 3 August; 187 entities in total). source ↗
What the markets are saying.
Daily closes, last six months. Source: Yahoo Finance; refreshed with each Global Watch edition (last update Oct 9, 2026, 6:37 AM KST). Indicators only, not investment advice.
Questions for your purchasing and risk teams
- Flag U.S.-bound products that contain inputs from UFLPA high-priority sectors such as aluminium, copper, lithium, steel, polysilicon, PVC or cotton.
- Match tier-2 and tier-3 suppliers and their parent companies, not just tier 1, against the UFLPA Entity List (187 entities as of 3 August 2026), and re-check whenever it is updated.
- Keep purchase, production and shipping records linked lot by lot; CBP's June 2026 guidance treats this as part of an importer's reasonable care.
- Write forced-labour bans, traceability data and cooperation with checks into supplier contracts.
- For each product, record the MFN rate, whether the forced-labour Section 301 tariff applies (12.5% including MFN) and whether it is a Section 232 product, and build this into costs.
- Indonesia (in force 15 April 2026), Cambodia (1 July) and Taiwan (announced 30 July) have also adopted forced-labour import restrictions; apply the same checks to products shipped there.
- Prepare the supply-chain map and evidence pack your U.S. customer will ask for.
What HELIOS does about it
- Matching suppliers, their parent companies and ownership against the UFLPA Entity List and U.S. sanctions lists.
- Continuous monitoring of list updates and CBP enforcement, with Korean-language executive alerts when a change touches your suppliers.
- Vision AI forensic checks of traceability records (purchase, production, shipping) and site photos for tampering.
- Ground Truth field verification, within the law, that supplier plants in Korea and Southeast Asia exist and are operating.
- U.S. Department of Homeland Security ↗
- Federal Register — notice-regarding-the-uyghur-forced-labor ↗
- U.S. Department of Homeland Security ↗
- 대한민국 정책브리핑 ↗
- Federal Register — initiation-of-section-301-investigations ↗
- Federal Register — notice-of-actions-in-section-301-investi ↗
- 법률신문 ↗
- KDI 경제정보센터 ↗
- 한국무역협회 (KITA) ↗
As of 2026-10-05. Figures are as published by each source. Not legal or investment advice.
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