SCRM Supplier Compliance & Risk Management

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Uyghur Forced Labor Prevention Act · United States

At US customs the presumption runs against you until you rebut it.

Goods linked to the Xinjiang region are presumed made with forced labour and are refused entry. The burden of proof sits with the importer, and it is a heavy one.

The UFLPA inverts the usual logic: the authority does not have to prove forced labour, the importer has to exclude it. Goods wholly or partly produced in the region, or sourced from listed entities, are caught – through cotton, polysilicon and aluminium that reaches textiles, solar modules and vehicle parts.

For Swiss exporters this is not remote. Supplying through a US subsidiary or a US customer puts you in the same evidential position. What decides it is the ability to document a chain back to the raw material – supply chain maps, invoices, production records.

Where it typically sticks

  • Cotton and textiles whose spinning mill cannot be named.
  • Polysilicon in solar modules and its precursors.
  • Aluminium and steel with input material of unclear origin.
  • Intermediaries unwilling to disclose their own upstream suppliers.

What is required

Chain map
Be able to name every stage back to the raw material, with company, site and role.
Records
Invoices, transport documents and production records per stage.
Due diligence system
A documented process that reviews the chain regularly.
Response time
Produce documents within customs deadlines – counted in days.
Alternatives
Sources outside the risk region prepared in advance.

How SCRM covers it

Multi-tier chain

Supplier, upstream supplier and production site linked instead of held in separate files.

Origin as a field

Country and region per commodity group, so exposure surfaces before customs asks.

Records on the entry

Documents where they will be looked for in a crisis.

Alternative sources

A vetted alternative for exposed positions rather than an idea.

Frequently asked

We do not ship to the US. Does it affect us?

Possibly indirectly. If your customer ships to the US they pass the evidence duty on, often word for word from what customs demands of them.

Is a supplier declaration enough?

Not on its own. What is required are documents that make the flow of goods traceable across the stages.

How does it relate to the EU forced labour regulation?

Both target the same thing with a different burden of proof. The underlying data is identical: know the chain and you serve both regimes.

As of July 2026. Not legal advice.

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