How do I screen a supplier for forced labor?

First, the UFLPA Entity List, published by DHS: goods made wholly or in part by a listed company are presumed to be made with forced labor and are barred from entry unless the importer rebuts the presumption. It held 186 entities as of August 3, 2026, and it grows by Federal Register notice.

Second, CBP's withhold release orders and findings under 19 U.S.C. § 1307. These are a separate mechanism: an order names specific goods from a specific producer, CBP detains those goods at every port, and a company can be under an active order without appearing on the Entity List at all. CBP publishes the active orders and findings on its own dashboard.

Third, the federal sanctions lists — OFAC's Specially Designated Nationals list and its consolidated non-SDN lists — and the Consolidated Screening List the International Trade Administration compiles from the export-control and sanctions lists of Commerce, State and Treasury. A supplier can appear there for reasons that have nothing to do with labor and everything to do with whether a U.S. company may deal with it.

Every list is keyed to a company's registered legal name and its known aliases, so the name on a quote or a marketplace listing is the wrong starting point: it is often a trading name, or a sales company one step removed from the factory. Ask for the registered name in English and, for a Chinese company, in Chinese characters, plus the name of the parent or group if there is one. The parent matters because the presumption reaches subsidiaries and affiliates of a listed entity.

A match proves one thing precisely: that the name, or an alias or parent of it, appears on a named list as of a dated copy of that list. That is a fact worth recording with its source and date, because it is what stands behind a decision months later.

A no-match proves less than it looks. It means nothing was found on those lists, under those names, on that date. It does not clear the goods, because forced-labor risk enters through raw materials and sub-suppliers upstream of the company on the invoice — DHS names cotton, polysilicon and tomatoes as priority sectors — and because a list changes after the day it was checked.

Shipment-history tools built on U.S. vessel-manifest data are a useful second look — a real supplier tends to show repeating, consistent shipments — but they have limits an importer should know before reading anything into a blank result. The data covers ocean cargo arriving in the United States; air, courier and non-U.S. shipments are not in it, and less-than-container cargo shows up under the consolidator's master bill rather than the supplier's name.

There is also a legal blind spot. Under 19 CFR 103.31, an importer or consignee can ask CBP to keep its name and address, and the names of its shippers, confidential in manifest data, and many established companies do. So a supplier with no public shipment record may be careful rather than fake. Trade data is good at ruling suppliers out; it does not confirm them.

A list screen — the government lists above, with the source and date behind each result — is the cheapest check and the one with legal weight at the border; it is priced in the tens of dollars. A corporate registry check, which confirms a company legally exists and who owns it, runs about $69 from one vendor whose public pricing is cited below, and a fuller investigation of lawsuits and standing about $199. Neither of those screens the government lists, and none of the three confirms that a factory can produce what it claims — only an on-site or live video audit does that, and it is quoted separately.

The cheap moment is before a deposit is paid, when a bad result costs a quote rather than a container. A supplier already in use is worth re-screening when a new Federal Register notice adds to the Entity List, when CBP issues a new withhold release order in the product's sector, and before any shipment that follows a long gap. This site keeps a public change log for each of the lists, so the date of the last change is never a guess.