Buyer sequence V13Before the order

Restricted-party screening: the list your own agency reads.

Every other check in the sequence reads a Chinese record. This one does not. The list belongs to your own customs authority, it binds you rather than the seller, and no China sourcing guide covers it because it is not a Chinese source.

· · 3-minute read

Prepared by Bao L. Zhou, Currawong’s China-side verification desk for international buyers.

V13 / SOURCE

What the list actually is.

In the United States the relevant source is the entity list published under the Uyghur Forced Labor Prevention Act. It is not one list. The statute names four, and the published page consolidates them. Each entry carries an effective date, and many entries carry former names and aliases in the same cell.

In the European Union there is no equivalent list. Regulation (EU) 2024/3015 prohibits products made with forced labour from the Union market and applies from 14 December 2027. It works as a market prohibition. There is no register of names to check a supplier against, so a buyer cannot discharge it with a lookup.

V13 / MEASURED

What we counted on 2026-09-08.

We read the published page and counted the rows under each statutory clause. The script that produced these numbers is in the repository and can be run again against the live page.

Rows under each statutory list, counted from the published page on 2026-09-08. One clause carries no entries at all.
ClauseWhat the list coversRows
2(d)(2)(B)(i)在新疆开采、生产或制造(全部或部分使用强迫劳动)的实体9
2(d)(2)(B)(ii)与新疆政府合作招募、运送、转移、窝藏或接收强迫劳动的实体47
2(d)(2)(B)(iv)把上述实体的产品从中国出口到美国的实体0
2(d)(2)(B)(v)在扶贫或对口支援等政府劳务计划下从新疆取得原料的设施与实体149

Three findings follow from that count, and each one changes how you build a screening list.

The published page carries 205 rows, and 67 of them name aliases or former names inside the same cell. Strip those and remove entries that appear under a second clause, and 193 distinct names remain. The announcement that accompanied the update states a different total again. We report all three and do not reconcile them, because the page alone does not let you reproduce the announced figure.

One statutory list, 2(d)(2)(B)(iv), has no entries. That is the list of entities that exported the goods into the United States. Its emptiness is covered on the exporter check, because it changes what you can learn about the party that ships to you.

An entry names a company. It does not describe a supply chain. A listed entity rarely sells to a foreign buyer directly, so a clear result on your immediate supplier says nothing about the tiers behind it.

V13 / METHOD

How to run the check.

Enter the registered Chinese name and the transliteration you hold, then repeat for any parent or affiliate the supplier discloses. Aliases matter here more than anywhere else in the sequence, because the list itself records them and a search on one spelling can miss an entry recorded under another. Record the list version date beside the result. That date is what makes the check reviewable later.

Screening belongs before the order, not before the shipment. A detention decision is made at your border, and by then the money has usually moved.

LIMITS

What a clear result does not prove.

A clear screen covers the name you entered and the list version you read on the day you read it. It does not cover entries added afterwards, suppliers further up the chain, or entities that were never listed. It is not a customs ruling, not legal advice, and not an assurance that a shipment will be released. Currawong does not screen on your behalf and does not maintain a copy of any government list. Currawong is the trading name of 济南深与国际贸易有限公司.

Related: the fourteen-step verification sequence · who exports your goods · what a registry check cannot prove.