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Modern slavery in the US: UFLPA, imports and supplier statements

Searches for a modern slavery act USA usually hit a gap: the United States has no single federal statute that mirrors the UK or Australian Modern Slavery Acts. What US importers and suppliers actually face is forced-labour import enforcement (especially the Uyghur Forced Labor Prevention Act) plus commercial asks for a modern slavery statement or policy in portals.

Modern slavery in the US: UFLPA, imports and supplier statements
Create my statement->What actually applies?

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Key takeaways

  • There is no federal US Modern Slavery Act that forces larger companies to publish an annual MSA-style statement the way the UK and Australia do.
  • US import risk is real: UFLPA (in force since 21 June 2022) creates a rebuttable presumption that goods tied to Xinjiang or listed entities are made with forced labour.
  • The DHS UFLPA Entity List names companies and facilities that trigger that presumption. Check it before you source or ship.
  • US buyers and portals still ask many vendors for a modern slavery statement or policy, even without a federal MSA filing duty.

Is there a Modern Slavery Act in the USA?

Short answer: no federal equivalent. The US does not have a nationwide transparency law that requires companies above a revenue threshold to publish an annual modern slavery statement on a public register. State proposals (including California-focused discussions people shorthand as a "California modern slavery act") are not a substitute for understanding federal import rules and customer contracts.

If a tender or portal asks for "your Modern Slavery Act statement", they usually mean a document in the same family as UK/AU statements: structure, supply chains, risks, actions, and how you review effectiveness. Produce that document for the commercial ask. Do not invent a US MSA citation that does not exist.

This page is about compliance documents and trade rules for businesses. It is not a history of slavery in America, and it is not legal advice.

What actually applies in the US

Four different pressures get muddled under "modern slavery USA". Separate them before you write anything.

What it isWho feels it
UFLPAFederal import law with a rebuttable presumption against goods linked to Xinjiang or listed entitiesImporters, manufacturers, and anyone whose BOM or supply chain touches high-risk geographies or listed parties
Tariff Act §1307Long-standing ban on importing goods made with forced labour; enforced with withhold-release orders and findingsAnyone bringing goods into US commerce
Portal / buyer askContract or onboarding request for a modern slavery statement or anti-slavery policyUS suppliers selling into large buyers, especially via Felix, Avetta, CM3, Ariba and similar
State / sector rulesNarrower disclosure or procurement rules that vary by state and industryEntities already under those regimes; check counsel for your footprint

UFLPA Entity List snapshot

Named entities on the DHS list sit inside the UFLPA presumption. Counts change when FLETF publishes additions. Use the official list, not a third-party copy, before you clear a shipment or approve a supplier.

Source dataU.S. Department of Homeland Security: UFLPA Entity ListU.S. government work (public domain) (checked today)
Entities on the published list
205

Row count at retrieval.

UFLPA signed into law
23 Dec 2021
UFLPA implemented
21 Jun 2022

Also the earliest add date on the list.

Latest addition on the list
3 Aug 2026as published

Basis: Published Entity List table rows on dhs.gov

How to prepare as a US supplier or importer

You cannot "UFLPA-certify" your way out of diligence with a one-page PDF. You can get the commercial documents and the import hygiene in order.

  1. 1

    Map products and origins

    Know which SKUs, materials and subcontractors touch China, Xinjiang-linked inputs, or other high-risk forced-labour categories CBP watches (electronics, apparel, agriculture and industrial inputs show up often in enforcement discussion).

  2. 2

    Screen the Entity List

    Check suppliers and facilities against the UFLPA Entity List. Build a repeatable screen into onboarding, not a one-off Google search.

  3. 3

    Write the portal documents

    Publish a clear modern slavery statement and, if buyers ask, a short policy. Say what you do in the US business, not what a UK Act requires you to file.

  4. 4

    Keep evidence for imports

    If you import, retain supply-chain evidence that can support a CBP review. A marketing statement is not a substitute for transaction-level records.

Statements vs import compliance

A modern slavery statement is a public narrative for customers, investors and portals. UFLPA compliance is an import-control problem: shipments can be stopped, denied or delayed when CBP applies the presumption. Doing one well does not finish the other.

If you also sell into the UK, Australia or Canada, you may have separate statutory reporting. See Modern Slavery Act UK, Modern Slavery Act Australia and Modern Slavery Act Canada. For risk worksheets, use the modern slavery risk assessment template.

Download the statement template

Get the editable Modern Slavery statement template, then fill it with US operations, supply-chain detail and the controls you actually run.

FAQs

What is UFLPA compliance?+
In practice it means knowing whether your goods or inputs could be tied to Xinjiang or to entities on the DHS UFLPA Entity List, and being ready to show clear and convincing evidence if CBP applies the rebuttable presumption. It is trade compliance, not a public register filing.
Is UFLPA still in effect?+
Yes. UFLPA was signed on 23 December 2021 and implemented on 21 June 2022. DHS continues to update the Entity List.
How do you comply with UFLPA?+
Map your supply chain, screen listed entities, avoid or remediate prohibited sources, and keep documentation that can support an exception if CBP reviews a shipment. Many importers also strengthen supplier contracts and audit rights. Get trade counsel for borderline cases.
What are high-risk sectors for UFLPA?+
CBP enforcement discussion and dashboards often highlight electronics (including solar), apparel and textiles, agriculture and industrial materials. Risk follows your bill of materials, not only your industry label.
Do US companies need a modern slavery statement?+
There is no general federal MSA filing duty. Many US companies still need a statement or policy because customers and supplier portals require one. Multinationals may also have UK, Australian or Canadian reporting duties for those footprints.
Does Australia have a modern slavery law?+
Yes. Australia’s Modern Slavery Act 2018 creates a Commonwealth reporting regime with a public statements register. See our Australia guide.

Related guides

Modern slavery statement template->Fillable statement structure for portals and buyers.Modern slavery policy template->Internal anti-slavery policy outline.Modern Slavery Act UK->Section 54 transparency rules and registry context.Modern Slavery Act Australia->Commonwealth reporting and the AU register.

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