Compliance Impact Report

Major Copper Supplier Makes the UFLPA Entity List

Zijin Mining Group — one of the world’s largest copper refiners — is now on the UFLPA Entity List.

On January 15, 2025, the Department of Homeland Security added Zijin Mining Group Co., Ltd. to its Uyghur Forced Labor Prevention Act Entity List. Z2 users had been alerted to the risk more than 200 days earlier.

Major copper supplier flagged under UFLPA forced-labor enforcement
~75% Of China’s copper reserves held by Zijin
200+ Days Z2 flagged Zijin before sanctioning
28 Sanctions lists Z2 monitors
16 Countries covered by those lists
15,000+ Entities on U.S. blacklists
25M People in forced labor globally
Overview

A new designation, no grace period

On January 15, the Department of Homeland Security (DHS) added Zijin Mining Group Co., Ltd. to its Uyghur Forced Labor Prevention Act (UFLPA) Entity List. The UFLPA is a U.S. law that prohibits the import of any products manufactured using forced labor, which the DHS defines as any situation where individuals are compelled against their will to provide work or service through the use of force, fraud, or coercion.

According to the DHS, as many as 25 million individuals are engaged in forced labor globally. For manufacturers, a designation like this carries immediate consequences: products with direct or indirect ties to a listed entity can be detained by Customs and Border Protection (CBP) the moment they reach the U.S. border.

Trade compliance often feels like firefighting. Entities are frequently sanctioned without warning, and companies are left scrambling to identify and remove them from supply chains as quickly as possible.

Overview of a major copper supplier's UFLPA compliance exposure

~75%

Of China’s copper reserves are held by Zijin, per a 2022 Sheffield Hallam University report.

12+

Countries where Zijin operates mines and factories, including Serbia, the DRC, and South Africa.

Who Is Zijin Mining Group?

One of the world’s largest copper refiners

Zijin Mining Group Co., Ltd. is a Chinese state-owned multinational that mines and processes copper, gold, zinc, lithium, silver, molybdenum, and other metal mineral resources from around the world. It operates factories and mines across more than a dozen countries, including Serbia, Kyrgyzstan, South Africa, Guyana, the Democratic Republic of Congo, and China.

Zijin is one of the world’s largest copper refiners and holds approximately 75% of China’s copper reserves, according to a 2022 Sheffield Hallam University report. The scale of its reach is exactly what makes a UFLPA designation so disruptive: a single listed supplier can touch countless downstream bills of materials.

What This Means for Manufacturers

Where to start

Manufacturers should begin removing any ties to Zijin in their direct or indirect supply chains to avoid having U.S.-bound products detained by CBP. There is no grace period, so the first moves matter.

Identify your exposure

Determine whether your company has direct or indirect ties to Zijin Mining Group Co., Ltd. or its subsidiary, Xinjiang Habahe Ashele Copper Co., Ltd. (aka Ashele Copper), anywhere in your tiered supply chain.

Secure alternatives

Communicate with your primary suppliers to confirm where their materials originate and secure alternative sources before shipments are detained at the border.

Monitor continuously

Track Tier 1 and sub-tier relationships against sanctioned and yet-to-be-sanctioned entities so the next designation is something you see coming, not something you scramble to react to.

Stay Ahead of Risk

Z2 saw Zijin’s sanctioning 200 days in advance

While Zijin Mining Group Co., Ltd. was officially added to the UFLPA Entity List on January 15, 2025, Z2 users saw it coming more than six months earlier. Thanks to real-time sanctions data and advanced analysis, Z2 flagged Zijin as a high-risk entity on June 13, 2024 — more than 200 days before it was officially sanctioned.

That same analysis found Zijin has major ties to a Tier 1 supplier in the automotive and electronics industries — exactly the kind of hidden, sub-tier connection that vendor questionnaires alone cannot surface.

200+ days

Z2 flagged Zijin as a high-risk entity on June 13, 2024 — more than 200 days before it was officially sanctioned.

The Z2 Solution

From reactive cleanup to proactive prevention

Z2’s Sanctions Watchlist leverages data and analytics to identify high-risk entities in your supply chain before they’re sanctioned by the U.S. or other governments. It maps Tier 1 and sub-tier supplier relationships against sanctioned and yet-to-be-sanctioned entities, making it easy to track connections, assess risk, and proactively mitigate threats. Z2 monitors 28 sanctions lists across 16 countries, including the U.S., Canada, France, Japan, China, and the U.K.

Supplier Insights

See your potential exposure to Zijin Mining Group Co., Ltd. — or any other sanctioned entity — by mapping your bill of materials against the entities Z2 tracks across 28 sanctions lists in 16 countries.

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Z2 Sanctions Watchlist mapping sub-tier supplier exposure to sanctioned entities

See your exposure before the next designation