CBP Data: Electronics Industry Struggles With Forced Labor Compliance
U.S. Customs and Border Protection data reveals significant forced labor compliance challenges for electronics importers; vast majority of value of shipments detained under UFLPA linked to electronics
Data from U.S. Customs and Border Protection (CBP) reveals that despite forced labor's stereotypical links to retail, apparel, and clothing imports, it is the electronics industry that is most financially affected by global laws governing modern slavery in product value chains.
The CBP data indicates that $3.1 billion worth of U.S. electronics imports have been subject to Uyghur Forced Labor Prevention Act (UFLPA) enforcement since the law was came into effect in 2022. This makes up close to 90% of the shipment value subject to UFLPA detentions.
Learn more about the extent of the electronics industry's forced labor compliance challenges and how Altana's product network offers electronics manufacturers and suppliers the visibility, traceability, and collaboration needed to secure product value chains and avoid violating the UFLPA, EU Forced Labour Regulation (EU FLR), and other forced labor laws.
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Electronics importers disproportionately affected by UFLPA enforcement
The UFLPA is a muscular forced labor regulation that establishes a rebuttable presumption that all goods mined, produced, or manufactured in Xinjiang or by entities on the UFLPA Entity List are produced with forced labor and barred from entering the U.S. This presumption includes goods' inputs — meaning that forced labor exposure in upstream suppliers, at Tiers 2, 3, 4 and beyond in the supply chain, can result in costly CBP seizures, delays, and detentions.
Since Xinjiang supplies 90% of China's cotton, and many suppliers added to the UFLPA entity list are associated with cotton, retail, and apparel, UFLPA enforcement is often associated with clothing. But in three years of enforcement, it's the electronics industry that has had billions of dollars of goods detained at the U.S. border.
$3.1 billion of electronics shipments have been detained from July 2022 to June 2025. This dwarfs the value of UFLPA enforcement in other sectors: $195 million in base metals, $92 million in apparel, $83 million in industrial goods, and $49 million in automotive parts.
The huge dollar value of the electronics sector's potential forced labor exposure belies a more even sectoral distribution of shipments affected by UFLPA enforcement. According to CBP's publicly available data, the automotive and aerospace industry has had the most individual shipments affected by UFLPA enforcement. Apparel and manufacturing have also been subject to significant enforcement.
The outsized dollar value of UFLPA detentions of electronics shipments is traced largely to a distinct raw material: polysilicon.
Xinjiang accounts for close to half the world's polysilicon production. Polysilicon is a vital component in semiconductors, photovoltaic cells, and integrated circuits and microchips that power industrial and consumer electronic products, including:
Solar panels
Smartphones and tablets
Computers and servers
Automotive electronics
Digital cameras
Televisions, tablets, displays, gaming consoles, household appliances, and other gadgets
Export Emergency: Electronics Industry Rocked by Export Controls
Electronics UFLPA violations exist upstream in product value chains
For the electronics industry, securing UFLPA compliance and reducing billions of dollars worth of import detentions carries a challenge: Exposure to possible forced labor violations is hidden upstream in product value chains.
CBP data indicates that the most common countries of origin for electronics shipments detained under the UFLPA are Malaysia, Vietnam, and Thailand. $0 of detained electronics shipment value has come from China.
The large volume of detained shipments from southeast Asia points to its status as a growing manufacturing hub for electronics. Electronics imports into the U.S. from southeast Asia have doubled in the last decade.
But raw goods and materials, like polysilicon, that are used to manufacture electronics components in southeast Asia often come from China, specifically Xinjiang.
The result, modeled below by an example from Altana's product network, is that Chinese forced labor is obscured far upstream in multi-tier product value chains, unseen and unanalyzed.
In this case, polysilicon from China goes to a Malaysian manufacturer of display panels. The Malaysian manufacturer sends the display panel component to India, which has a growing electronics assembly industry, to assemble the display panel into a completed laptop. The country of origin is India, the manufactured component comes from Malaysia, but sub-tier exposure to a Xinjiang mining operation on the UFLPA Entity List could flag the shipment for CBP detention.
Given the Gartner finding that only 17% of Chief Procurement Officers have visibility into Tier 3 suppliers, it’s likely that many electronics brands, electronics importers, and even Tier 1 suppliers:
Don’t presently have an honest accounting of their vast, business-critical exposure to entities flagged by the UFLPA Entity List or other forced labor laws
Can't pinpoint which specific product lines are at risk of delays, detentions, and disruption
Haven't found a reliable way of sourcing new, compliant suppliers
Get electronics value chain visibility, traceability, and collaboration with Altana’s product network
Unlike tired supply chain technology that requires burdensome and inaccurate manual mapping, risk screening tools, and supplier surveys, Altana’s product network enables electronics manufacturers, businesses, and consumer brands to illuminate, design, and collaborate across product-level value chains to identify and mitigate potential forced labor violations.
Visibility means getting an instant, dynamic map of N-tier relationships at a product level. AI reveals specific multi-tier product value chain connections and uncovers hidden relationships and risks, such as upstream exposure to entities flagged on the UFLPA Entity List.
Traceability means having detailed data and documentation on a product’s lifecycle, as verified by upstream suppliers, to confirm a lack of upstream Xinjiang exposure.
Collaboration means closer relationships and more real-time communication with government agencies and regulators to clear borders faster. Altana Product Passports can be used to collaborate with upstream and downstream supply chain partners, specifically allowing electronics to work directly with CBP to pre-validate their shipments' UFLPA compliance
