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SPECIAL SUPPLY CHAIN REPORT

Uyghur Forced Labor

Prevention Act
Created by Resilinc Risk Analysis Team
Updated: July 8, 2022

© 2022 Resilinc Corporation. All rights reserved.

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Table of Contents & Executive Summary

Uyghur

S-1: Uyghur
Forced Within this special report we review
Labor updates to the Uyghur Forced Labor
Prevention Prevention Act and cover important

Forced Labor
Act
topics including what new legislation
has been passed, the DHS entity list, the

Prevention Act
targeted and most vulnerable industries,
and more.

We've also included best practices

and immediate next steps you should

S-2: DHS Entity take to protect your supply chains.

List
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Uyghur Forced Labor Prevention Act

• The Uyghur Forced Labor Prevention Act went into full force on June 21st. The US has banned imports from the
Xinjiang Uyghur Autonomous Region (XUAR) due to evidence of widespread forced labor across many
industries
• 0.01% of total goods imported into the US come directly from the XUAR, totaling $300M, this according to a 2019 report
from the Center for Strategic & International Studies (CSIS)
• Note that the number above does not consider the many raw materials that come out of the XUAR and are used for
production of goods that come to the US
• Customs and Border Protection (CBP) will be issuing letters to importers identified as having previously
imported merchandise that may be subject to the Trafficking in Persons (TIP) Act
• Customs officials have been given guidance on what they should look for when goods are seized under the
Trade Union and Labor Relations (TULR)
• Guidance is also expected from the Bill and Melinda Gates' Forced Labor Enforcement Task Force's (FLETF)
• The US government has sanctioned, and designated Xinjiang-based companies and products as associated with
forced labor
• These include US sanctions and export controls on Xinjiang Production and Construction Corps (XPCC) entities. All
of these entities are complying with US Sanctions, Export Controls, CBP, and Department of Labor requirements
and guidance
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Uyghur Forced Labor Prevention Act
• The UFLPA will require the CBP to
apply a “rebuttable presumption” to
any goods that are produced wholly or
in part in the XUAR or by an entity
included on one of the forthcoming
entity lists
• Rebuttable presumption is an
assumption made by court taken to be
true until proven otherwise. Meaning
those impacted are guilty until proven
innocent
• Companies must provide “a
comprehensive supply chain mapping,
a complete list of all workers at an
entity subject to the rebuttable
presumption in the production of the
imported good, and proof that workers
were not subject to conditions typical
of forced labor practices” (CSIS)
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Department A comprehensive assessment of the risk of importing goods mined,
of produced, or manufactured, wholly or in part, with forced labor in the People’s
Homeland Republic of China (PRC)
Security An evaluation and description of forced labor schemes, UFLPA-required lists,
Strategy UFLPA required plans, and high priority sectors for enforcement
Recommendations for efforts, initiatives, tools, and technologies to
accurately identify and trace affected goods
A description of how CPB plans to enhance its use of legal authorities and
tools to prevent entry of goods at US ports in violation of 19 U.S.C. § 1307
A description of additional resources necessary to ensure no goods made
with forced labor enter US ports
Guidance to importers
A plan to coordinate and collaborate with appropriate NGOs and private-
sector entities
Source: https://www.dhs.gov/sites/default/files/2022-06/22_0617_fletf_uflpa-strategy.pdf
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High Priority Sectors for Enforcement

Sector Companies with WRO’s before the UFLPA was enacted Now: After UFLPA – “rebuttable
presumption” that the good is
prohibited from entry
Polysilicon Products from one company: Hoshine Silicon Industry Co., Ltd. and All polysilicon produced in the XUAR
its subsidiaries
Apparel Products from three companies: All apparel products produced in the
1. Baoding LYSZD Trade and Business CO., Ltd. XUAR
2. Hetian Taida Apparel Co., Ltd (and one alias: Hetian TEDA
Garment)
3. Yili Zhuowan Garment Manufacturing Co., Ltd.
Tomatoes All raw tomatoes and tomato products produced in the XUAR* All raw tomatoes and tomato
* WRO effective beginning 1/13/21 products produced in the XUAR
Cotton All cotton produced in XUAR* and all cotton produced by two All cotton and cotton products
companies: produced in XUAR
1. Xinjiang Production and Construction Corps (XPCC)
2. Xinjiang Junggar Cotton and Linen Co., Ltd.
* WRO released on 12/2/20
Source: CSIS

All cotton and tomato products subject to New additions to industry

WRO’s before UFLPA was enacted wide bans in XUAR region
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Immediate Next Steps

• Many enterprises at the large and

small level are in question regarding
what steps to take to abide by the
legislation
Forced Labor Warning Signs – The Advisory
• Immediate next steps you should take
1. to prepare:
2. 1. Assess if any of your Tier 1 suppliers
Operating within
or near 3. are in the XUAR region, although the
internment High revenue act requires that no forced labor is
camps, prisons, with few used in any of your tiers
employees “Nonstandard
or industrial hiring practices”
parks paying into the 2. Understand your bill of materials for
government’s such as hiring all merchandise, goods, and parts, to
social security workers through
see how deep your supply chain goes
insurance govt. recruiters
program 3. Gather documents for suppliers of all
tiers regarding: customs entry
documents for finished goods, proof
of payment documents, and
transportation documents

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What to Expect - Uyghur Forced Labor Prevention Act
Wait and See Approach
Where • Not prepared to commit resources
or investment to take preventive
you are action
• Hoping for best case to work itself
out
• Some internal prep and discussion
• No playbooks or action plans being
put in place
• Supply chain information not
centralized
• No monitoring of suppliers or
events
• Expect situation to resolve
• Plan to react as needed at the time
• React to shortages and supplier
What issues on the fly
you can • In WarRooms with executives,
boards, answering questions
expect • Losing suppliers, goods or parts,
due to the region they are
manufactured, mined, or exported
from
• Goods being blocked from entering
the US if thought to be made with
forced labor
• Implementation of the law in June
2022
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Feel Ready Relying on
People
• Have gathered information about
dependencies from supplier
commodity managers
• Have some data about suppliers
relying on supplies/locations in the
XUAR
• Anticipating impact and working
with suppliers with available
information
• No centralized command and
control or information repositories
• Information slow to make its way
up the chain
• Analyze best actions or response
measures
• Coordination across global teams
• Allocations, shortages, lines down,
customer impact
• Financial impact (profits and
revenue)
• Retaliatory tariffs from China
affecting imports and exports of
goods
Carefully protecting knowns →
Have a lot of supplier information
• Have supplier intelligence centralized
• Have developed monitoring for developing
events
• Commodity Market tracking – prices to
rise
• Have developed scenarios
• Planning for worst case
• Relying on suppliers to protect supply
continuity
• Impacted companies have until March 10,
2022, to put their comments to the USG
• Able to manage a lot of knowns, scenarios,
and risks
• Team coordinating better across geos and
time zones
• Some allocations, lines down, supply chain
impact will be felt depending on
developments
• Lots of talk about “what can we learn and
do better”
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Anticipating, Collaborating,
Monitoring, Acting
• Have multi-tier SC mapped, part-site info for
all high impact products
• Have already identified all suppliers and
sites in all affected regions relying on
materials and energy supplies from XUAR
• Have already required suppliers to plan for
and present action plan
• Supplier screening, and change suppliers if
needed
• Have analyzed supply chain impact and
triggered action to protect supplies in
various regions
• Risk assessments to prove forced labor was
not used
• Streamlined information flow and faster
response times
• Suppliers at backup sites in place
• Top revenue (or highest impact) products
already secured
• Well-coordinated and effective team
• Continuous monitoring and corrective
actions being taken
• Collaboration with suppliers ongoing
• Team is motivated and feels in control
• Leadership team, BOD and customers have
confidence in supply chain organization
• Despite revenue/customer impact,
confidence in the team remains strong
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Resilinc Solutions

• Resilinc provides transparency and visibility in the sourcing process by helping companies monitor and assess for
slave and forced labor in supply chains. We do this through solutions such as: Multi-tier mapping, EventWatchAI,
RiskShield, and more

Identify if any non- Identify

Discover any sanctioned suppliers with
sanctioned suppliers in
suppliers part of your an elevated
your supply chain
supply chain risk of slave
operate in the XUAR
labor use

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SECTION #2

DHS Entity List

Updated 7/6/2022

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DHS Entity List

• The entity list shows enterprises, where if imported from, will be subject to rebuttable presumption
• Some companies on this list already had a withhold release order (WRO) meaning that they were previously
prohibited from exporting goods into the US due to the use of forced labor

Sectors: Rail-Transportation Equipment

*The DHS Entity List is included in Resilinc EventWatchAI monitoring*

Name of Entity Previously Subject to WRO by Name?

KTK Group (including three aliases: Jiangsu Jinchuang Group; Jiangsu Jinchuang No
Holding Group, and KTK Holding)

Sectors: “Reeducation” Internment Camp

Name of Entity Previously Subject to WRO by Name?
No. 4 Vocation Skills Education Training Center (VSETC) Yes
Source: CSIS

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DHS Entity List
Sectors: Textiles, Clothing, Apparel, Hair Products, Garments, Cotton and Cotton Products, Processed Cotton

Name of Entity Previously Subject to WRO by Name?

Baoding LYSZD Trade and Business Co., Ltd. Yes
Hetian Haolin Hair Accessories Co. Ltd. (including two aliases: Hotan Haolin Hair Yes
Accessories; and Hollin Hair Accessories)
Hetian Taida Apparel Co., Ltd (including one alias: Heitan TEDA Garment) Yes
Lop County Hair Product Industrial Park Yes
Lop County Meixin Hair Products Co., Ltd. Yes
Xinjiang Production and Construction Corps (including three aliases: XPCC; Xinjiang Yes
Corps; and Binghuan and its subordinate and affiliated entities)
Xinjiang Junggar Cotton and Linen Co., Ltd. Yes
Yili Xhuowan Garment Manufacturing Co., Ltd. Yes
Aksu Huafu Textiles Co. (including two aliases: Akesu Huafu and Aksu Huafu Dyed No
Melange Yarn)
Changji Esquel Textile Co. Ltd. (including one alias: Changji Yida Textile) No
Nanjing Synergy Textiles Co., Ltd. (including two aliases: Nanjing Xinyi Cotton Textile No
Printing and Dyeing and Nanjing Xinyi Cotton Textile)
Source: CSIS

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 DHS Entity List
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Sectors: Computer Parts, Electronics, Touch Screens for Handheld Devices and Cars, Other Similar Products

Name of Entity Previously Subject to WRO by Name?

Hefei Bitland Information Technology Co., Ltd. (including three aliases: Anhui Hefei Yes
Baolongda Information Technology; Hefei Baolongda Information Co., Ltd.; and
Hefei Bitland Optoelectronic Technology Co., Ltd.)

Hefei Meiling Co. Ltd. (including one alias: Hefei Meiling Group Holdings Limited) No

Tanyuan Technology Co. Ltd. (including five aliases: Carbon Yuan Technology; No
Changzhou Carbon Yuan Technology Development; Carbon Element Technology;
Jiangsu Carbon Element Technologu: and Tanyuan Technology Development)

Source: CSIS

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DHS Entity List
Sectors: Silica-Based Products, Polysilicon, Including Solar-Grade Polysilicon

Name of Entity Previously Subject to WRO by Name?

Hoshine Silicon Industry (Shanshan) Co., Ltd (including one alias: Hesheng Silicon Yes
Industry, or Shanshan Co.) and subsidiaries

Xinjiang Daqo New Energy, Co. Ltd (including three aliases: Xinjiang Great New No
Energy Co., Ltd.; Xinjiang Daxin Energy Co., Ltd.; and Xinjiang Daqin Energy Co.,
Ltd.)

Xinjiang East Hope Nonferrous Metals Co. Ltd. (including one alias: Xinjiang No
Nonferrous)

Xinjiang GCL New Energy Material Technology, Co. (including one alias: Xinjiang No
GCL New Energy Materials Technology Co.)

Source: CSIS

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