Buyer sequence V13Before the order

UFLPA Entity List: supplier name screening and limits

Check which restrictions apply to your goods, destination and parties before you commit. This guide explains one US forced-labour list and its limits. It is not a complete restricted-party screen or a clearance decision.

· · 3-minute read

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

V13 / SOURCE

What the list actually is.

The DHS UFLPA Entity List addresses a specific US forced-labour import regime. It does not replace sanctions or export-control checks. For applicable US exports, reexports or transfers, the Consolidated Screening List brings together several agencies’ lists. Denied party screening is the common name for checking a party against those lists. Read the source agency’s rules before acting on a possible match.

A name can be absent from a list while ownership rules still apply. For example, OFAC FAQ 401 says entities owned 50% or more in aggregate, directly or indirectly, by blocked persons are themselves blocked. Other lists have their own ownership rules. Check relevant owners and the rules for your transaction. CSL and OFAC guidance consulted 9 September 2026.

The EU has a different forced-labour framework. Regulation (EU) 2024/3015, Article 39, sets general application from 14 December 2027, with some provisions applying earlier. Article 8 provides for a risk database covering areas and products. It is not a supplier clearance list; a name lookup alone does not establish compliance.

V13 / MEASURED

205 entries do not mean 205 separate entities.

We counted 205 entries across the four lists: 9, 47, 0 and 149. Our 7 September count of the DHS webpage and a 23 September recount of the 3 August 2026 Federal Register appendix give the same rows. After text cleanup, the 7 September count found 193 distinct name strings, with alias wording in 67 entries; those two figures depend on the cleanup rule, and the notice itself states 187 entities. It checks that dated edition, not the current DHS webpage or the number of separate legal entities. Use the official list for a new screening check.

View the four lists and counting limits
Entries in the 3 August 2026 edition, recounted 23 September 2026. Clause descriptions are short English summaries.
ClauseWhat the list coversRows
2(d)(2)(B)(i)Entities producing goods in Xinjiang using forced labour9
2(d)(2)(B)(ii)Entities working with the Xinjiang government on forced-labour recruitment or transfers47
2(d)(2)(B)(iv)Entities exporting covered goods from China to the United States0
2(d)(2)(B)(v)Entities or facilities sourcing material from Xinjiang through specified labour programmes149

We removed selected parenthetical alias suffixes, lowercased names and normalized punctuation before counting distinct strings. Text cleanup is not legal-entity matching: the notice itself reports 187 entities. Under clause 2(d)(2)(B)(iv), it identifies no additional exporters beyond those already covered by clauses (i) and (ii). Our zero counts additional entries there; it does not mean an exporter is unrestricted. The recount does not recover our original 7 September DHS webpage capture.

A company name does not describe a supply chain. A clear result for the immediate supplier does not establish the status of its upstream parties. Separately identify who will export your shipment.

V13 / METHOD

How to run denied party screening.

Enter the registered Chinese name and the transliteration you hold, then repeat for any parent or affiliate the supplier discloses. A search on one spelling can miss an alias. Compare identifiers as well as names; a similar name is a possible match, not a confirmed identity. Record the list version date beside the result. That date is what makes the check reviewable later.

Start screening before the order and revisit it before payment or shipment when the parties, goods or lists change. Save possible matches and how each was resolved.

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.

How we counted the list

We read the published appendix clause by clause and count the rows under each clause. Where one entity appears with aliases or former names, we count that entity once and record the alias lines separately. That is why a row total and an entity total differ on the same list.

Every count is stored with the list version date and the date we read it. A count describes what the published list contained on the day it was read. It does not tell you whether your goods may enter, and it does not carry forward to a later version of the list.

Name came back clear? Record the list version and the date you read it. A clear name search is a dated act on one list. It is no clearance decision for your shipment.

Still need to know who will actually export the goods? The exporter of record check covers the party named on the transport documents.