August 2026 UFLPA Entity List Expansion
Z2's breakdown of the 43 new UFLPA Entity List additions: who they are, which industries they reach, and the four sanctioned companies with the deepest ties to U.S. supply chains.
On July 31, the U.S. Department of Homeland Security announced that it would be adding 43 new businesses to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. The DHS’s announcement, which entered into force on Monday, August 3, represented a significant jump in the number of entities sanctioned by the UFLPA. As the DHS press release noted, the expansion is a 30% increase in the number of organizations on the Entity List, as well as the “single largest-ever expansion of the List.”
The development is especially notable because of the context in which it has occurred. Prior to the July 31 announcement, the Trump administration did not appear particularly interested in the UFLPA and the laws and sanctions surrounding it. The last time any companies were added to the UFLPA Entity List was on January 15, 2025—nearly a week before President Trump and his administration entered office. Some businesses and industries may have even grown complacent, assuming that the 144 entities sanctioned under the UFLPA would stay fixed at that number for the foreseeable future.
The DHS’s recent measures change all that. Now, the UFLPA has imposed new responsibilities on American companies to identify Chinese entities in their supply chain utilizing forced labor and root them out.
It’s worth emphasizing that the UFLPA is an actively enforced law. Customs and Border Protection (CBP) agents are screening customs declarations using sophisticated software, looking for potential links to sanctioned entities or products coming from the Xinjiang Uyghur Autonomous Region (XUAR), the epicenter of China’s forced labor programs. These shipments, and products coming from these sources, are subject to detention and/or seizure by CBP. In fact, the DHS has maintained statistics on UFLPA detainments dating back to 2022, when the law was first enacted. To date, several billions of dollars’ worth of goods have been seized or detained at the border under the UFLPA.
While detainments dropped significantly when Trump entered office in 2025, the recent expansion of the UFLPA Entity List could signal an impending ramp-up in enforcement. U.S. businesses should be prepared to face full CBP scrutiny of their imports.
At the end of July, the Department of Homeland Security announced UFLPA sanctions on 43 new entities. These Chinese businesses span a range of industries, including mining, metal production, electronic component manufacturing, and biopharmaceuticals.
Z2’s Sanctions Watchlist identified many of these Chinese companies as being at risk for sanctions long before the announcement from the Department of Homeland Security on July 31. Businesses that used Z2’s sanctions forecasting tool were able to see the trade compliance threat these businesses posed before they were officially sanctioned, giving them the opportunity to alter their sourcing or make other strategic modifications.
Below, we’ve broken down the newly sanctioned entities into four categories:
We’ve also included descriptions of the industries these entities operate in, as well as the type of manufacturing they engage in.
| Chinese Entity Sanctioned on July 31 | Industry and Manufacturing Details |
|---|---|
| Shandong Gold Mining Co., Ltd. (also known as Shandong Gold) | Gold mining, exploration, ore processing, and sale of gold and related mineral products. |
| Shandong Gold Smelting Co., Ltd. | Gold and precious-metals smelting, refining and processing. |
| Baiyin Nonferrous Group Co., Ltd. (also known as Baiyin Nonferrous; and BNMC; and formerly known as Baiyin Nonferrous Metals Company) | Non-ferrous metals group engaged in mining, beneficiation, smelting, refining and trading of copper, lead, zinc, gold and silver. |
| Xinjiang Baiyin Mining Development Co., Ltd. | Mining and development of non-ferrous and precious-metal resources, including gold mining operations. |
| Jiangsu Tiangong Technology Co., Ltd. | Titanium sponge, titanium ingots and titanium-alloy materials/products for industrial and high-performance applications. |
| Baoji Jucheng Titanium Industry Co., Ltd. | Titanium and titanium-alloy materials and fabricated products, including bars, sheets, tubes, wire and custom titanium equipment. |
| Xinjiang Tianchi Energy Co., Ltd. | Coal mining, coal sales and integrated energy operations supporting power and industrial customers. |
| Shihezi Xinren Battery Aluminum Foil Technology Co., Ltd. | Battery-grade aluminum foil and related rolled aluminum materials for lithium-ion battery applications. |
| Tianshan Aluminum Group Co., Ltd. (formerly known as Shimge Pump Industry Group Co., Ltd.) | Vertically integrated aluminum producer covering bauxite/alumina, primary aluminum, carbon anodes, high-purity aluminum and battery foil. |
| Xinjiang Production and Construction Corps Eighth Division Tianshan Aluminum Co., Ltd. (also known as Tian Aluminum Co., Ltd.) | Primary aluminum and integrated aluminum production; principal operating affiliate within the Tianshan Aluminum group. |
| Xinjiang Tianzhan New Material Technology Co., Ltd. | High-purity aluminum and advanced aluminum materials. |
| Jiangyin Xinren Aluminum Foil Technology Co., Ltd. (also known as Xinren Aluminum Foil) | Rolled aluminum products, particularly aluminum foil, coil and sheet used in industrial and packaging applications. |
| Jiangyin Xinren Aluminum Technology Co., Ltd. (also known as Xinren Aluminum) | Aluminum technology and manufacturing, including non-ferrous alloy development, aluminum rolling and related materials. |
| Xinjiang Jinchuan Mining Industry Co., Ltd. (also known as Xinjiang Jinchuan Company) | Gold and mineral exploration, mining, beneficiation and related processing. |
| Chinese Entity Sanctioned on July 31 | Industry and Manufacturing Details |
|---|---|
| TBEA Co., Ltd. | Power transmission and distribution equipment, transformers, cables, renewable-energy systems and energy/infrastructure engineering. |
| Hunan Aihua Group Co., Ltd. (also known as Aihua Group and AiSHi) | Electronic components, primarily aluminum electrolytic capacitors and film capacitors, with upstream electrode foil and equipment capabilities. |
| Henan Guorong Electronic Technology Co., Ltd. (also known as Goroe; and Guorong Shares) | Electronic materials, especially formed/aluminum electrode foil used in aluminum electrolytic capacitors. |
| Chinese Entity Sanctioned on July 31 | Industry and Manufacturing Details |
|---|---|
| SDIC Xinjiang Luobupo Potash Co., Ltd. (also known as SDIC Xinjiang Lop Nur Potash Co., Ltd.) | Potash chemicals and fertilizers, especially potassium sulfate produced from Lop Nur brines. |
| SDIC Xinjiang Lithium Industry Co., Ltd. | Lithium chemicals, principally lithium-carbonate production from Lop Nur brine resources. |
| Alar Nanjiang Carbon New Material Co., Ltd. | Carbon materials for the aluminum industry, including prebaked carbon anodes used in primary aluminum smelting. |
| Xinjiang Tianshan Yingda Carbon Co., Ltd. | Carbon products for aluminum smelting, including prebaked anodes and other aluminum-industry raw materials. |
| Xinjiang Tianhongji Technology Co., Ltd. (formerly known as Xinjiang Tianhongji Silicon Industry Co., Ltd.) | Lithium-ion battery materials, especially graphite-based anode materials and related carbon products. |
| Yili Chuanning Biotechnology Co., Ltd. (also known as Twinings Bio; and CN BIO) | Biotechnology fermentation and pharmaceutical intermediates, including antibiotic intermediates and bio-based products. |
| Xinjiang Nuziline Bio-Pharmaceutical Co., Ltd. (also known as Xinjiang Xinziyuan Biopharmaceutical Co., Ltd.) | Biopharmaceutical and hormone medicines, including conjugated-estrogen active ingredients and finished dosage forms. |
| Guangxi Kelun Pharmaceutical Co., Ltd. | Pharmaceutical manufacturing, including injections, active pharmaceutical ingredients, intermediates and other medicines. |
| Nanjing Lilai Pharmaceutical Technology Co., Ltd. | Pharmaceutical research and development, including steroid-drug intermediates, impurities, active ingredients and process development. |
| Tefeng Pharmaceutical Co., Ltd. (also known as Tefeng Pharmaceutical; and formerly known as Tefeng Health Technology Co., Ltd.) | Pharmaceutical development and manufacturing, with a focus on steroid and specialty-drug products and intermediates. |
| Xinjiang Tefeng Pharmaceutical Industry Co., Ltd. | Pharmaceutical manufacturing and R&D, including steroid medicines, active ingredients and intermediates. |
| Xinjiang Tianshan Snow Lotus Pharmaceutical Co., Ltd. | Traditional Chinese medicine and pharmaceutical products based on snow-lotus and other botanical ingredients. |
| Xinjiang Biochemical Pharmaceutical Co., Ltd. | Pharmaceutical manufacturing, including biochemical and digestive-system medicines. |
| Xinjiang Huashidan Pharmaceutical Co., Ltd. | Pharmaceutical manufacturing, including oral liquids, tablets, capsules and injectable medicines. |
| Chinese Entity Sanctioned on July 31 | Industry and Manufacturing Details |
|---|---|
| Xinjiang Communications Construction Group Co., Ltd. | Transport infrastructure construction, including highways, bridges, municipal works and related engineering services. |
| Xinjiang Tianyun Organic Agriculture Co., Ltd. | Aquaculture and food processing, centered on freshwater salmon farming, processing and sales. |
| Henan Tongzhou Cotton Industry Co., Ltd. | Cotton procurement, ginning, processing and trading, with yarn, fabric, garments and textile supply-chain operations. |
| Chalkis Health Industry Co., Ltd. (formerly known as Xinjiang Chalkis Co., Ltd.) | Tomato processing and food ingredients, including tomato paste, tomato products and related agricultural processing. |
| Chacha Food Company, Limited (also known as Chacha Food Co., Ltd.; Qia Qia Food; and Chia Chia Food Co., Ltd.) | Packaged snack foods, especially roasted seeds and nuts, nut products and other leisure foods. |
| Fujian Septwolves Industry Co., Ltd. (also known as Septwolves) | Apparel and fashion products, principally branded menswear, clothing and accessories. |
| Zhengzhou Synear Food Co., Ltd. | Quick-frozen and prepared foods, including dumplings, rice balls, noodles and other frozen convenience foods. |
| Shandong Weiqiao Pioneering Group Co., Ltd. (also known as Shandong Weiqiao Chuangye Group Co., Ltd.; and Shandong Weiqiao Venture Co., Ltd.) | Integrated textile manufacturing spanning cotton yarn, fabric, dyeing, apparel/home textiles and supporting industrial operations. |
| Shandong Weiqiao Textile Technology Co., Ltd. | Cotton textiles, including cotton yarn, grey fabric and denim production and sales. |
| Aksu Aodu Sugar Industry Co., Ltd. | Sugar manufacturing; processes sugar beets/cane into refined sugar and related products. |
| Kashgar Aodu Sugar Industry Co., Ltd. | Sugar manufacturing and processing. |
| Kashgar Jiangguoguo Agricultural Technology Co., Ltd. (also known as Jiangguoguo) | Agricultural-product processing, focused on walnuts and other nut/fruit products. |
The reach of the 43 Chinese companies the DHS added to the UFLPA Entity List in August extends far and wide. Many of the sanctioned Chinese entities are sub-tier suppliers who provide critical materials like gold, tin, and polysilicon to tier 1 manufacturers, either directly or through other sub-tier producers. In other cases, these sanctioned companies produce components like aluminum electrolyte capacitors that are used by a broad range of high-tech manufacturers, giving them a foothold in a wide breadth of sectors and supply chains.
In this section, we drill down on four of the newly sanctioned Chinese entities that have the largest footprint in industries like automotive, consumer electronics, industrial manufacturing, and medical technology. We chose these four companies because they had—by a significant margin—the most direct or indirect links to tier 1 suppliers in our database.
In addition to summarizing the companies and outlining the industries and products they are most frequently tied to, we’ve also included the number of supply chain connections these entities were found to have in our internal Z2 databases. These figures represent the number of discrete links between the sanctioned entity and a tier 1 supplier or original equipment manufacturer (OEM).
(Note: a sanctioned entity can have dozens or even hundreds of links to a single tier 1 supplier, either directly or, more often, indirectly.)
Probable Supply Chain Links: 101,552
Headquartered in the city of Jinan in Shandong province, Shandong Gold Mining is a firm focused on the mining, smelting, and refining of gold and gold products. Shandong Gold Mining’s parent company, Shandong Gold Group, is a state-owned business controlled under the provincial government of Shandong.
Industries
Consumer electronics; audiovisual equipment; semiconductor manufacturing; robotics; data centers.
Products
Printers, barcode scanners, automobiles, power tools, Internet of Things (IoT) hardware, chip testing equipment, oscilloscopes, logic analyzers.
Probable Supply Chain Links: 75,781
Shandong Gold Smelting is a major subsidiary of Shandong Gold Mining, and is primarily engaged in the smelting of gold and other precious metals. In addition to gold, Shanding Gold Smelting also works with silver, copper, lead, and zinc.
Industries
Consumer electronics; industrial technology; audiovisual equipment; semiconductor manufacturing; medical technology.
Products
Oscilloscopes, gas detection systems, thermal imaging equipment, audiovisual equipment, power tools, computer hardware, diagnostic tools, laboratory equipment.
Probable Supply Chain Links: 7,709
Similar to Shandong Gold Mining, the Baiyin Nonferrous Group is engaged in the mining, smelting, and refining of various precious metals, including gold, silver, copper, lead, and zinc. And like Shandong Gold Mining, Baiyin Nonferrous is state-owned, in this case under the auspices of the Gansu provincial government.
Industries
Communications hardware; semiconductor manufacturing; industrial manufacturing; electronic testing equipment.
Products
Chip and memory testing equipment, modems, gateways, antennas, loudspeakers, amplifiers, satellites, microinverters, battery storage systems.
Probable Supply Chain Links: 2,525
Headquartered in Yiyang City in Hunan province, the Aihua Group designs and manufactures aluminum electrolyte capacitors, film capacitors, electrode foils, and other related products through its AiSHi brand. Because of the wide range of uses for its products, the Aihua Group serves a myriad of global industries.
Industries
Automotive; data centers; medical technology; industrial manufacturing; home energy technology.
Products
Solar micro-inverters, battery storage systems, EV charging stations, data center infrastructure, health monitoring devices, audio equipment, HVAC systems, pacemakers, defibrillators, gas monitors.
Probable supply chain links by sanctioned company
Nobody wants to be on the wrong side of a UFLPA detention at a U.S. port of entry. Businesses can spend weeks or longer fighting these detentions, a money pit that requires companies to commit resources to trade compliance law firms and warehouses, while allocating company bandwidth to the lengthy process of trying to reclaim shipments. And while it’s still too early to say whether the Trump administration plans to ramp up enforcement of the UFLPA, the recent expansion of the Entity List suggests that it’s a strong possibility.
To effectively navigate the risk of Chinese forced labor in your supply chain, organizations should look to adopt both a proactive and a reactive approach. For companies focused on determining their exposure right now, reactive risk management is required.
To gauge their sanctions exposure, businesses need to access supply chain relationship data that shows them whether any of the newly sanctioned companies are connected to their tier 1 or tier 2 suppliers. Z2 can help with this by providing customers access to internal databases with supply chain relationship data that connects their direct suppliers to sub-tier entities all over the world. Z2’s internal supply chain relationship database provided the foundation for this report, identifying over 180,000 links between the newly sanctioned entities and other suppliers and original equipment manufacturers (OEMs).
Businesses that identify connections between their direct suppliers and newly sanctioned entities can then carry out several risk mitigation steps:
With part-to-site mapping, an industry-leading crosses tool, and a database with over one million suppliers, Z2 can help companies with all of these steps.
In addition to leveraging a tool like Z2, businesses should also contact their direct suppliers and confirm that no entities on the UFLPA Entity List are part of the supply chain for materials, components, or other goods that go into their products.
To proactively mitigate the threat of sourcing from businesses using forced labor, companies can draw on supply chain intelligence that shows them the businesses at the highest risk of being sanctioned in the near future.
Z2 offers this type of intelligence through its proprietary Sanctions Watchlist, a tool that forecasts probable future sanctions. The Sanctions Watchlist uses government reports, news publications, regulatory filings, and other high-credibility sources to identify entities at high risk of being sanctioned in the future, giving users the insights and visibility to preemptively clean up their supply chains.
To learn about how Z2 helps businesses manage compliance risks both proactively and reactively, schedule a free trial with one of our product experts.
Z2 offers this type of intelligence through its proprietary Sanctions Watchlist, a tool that forecasts probable future sanctions. The Sanctions Watchlist uses government reports, news publications, regulatory filings, and other high-credibility sources to identify entities at high risk of being sanctioned in the future, giving users the insights and visibility to preemptively clean up their supply chains.
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