WRC Update to Licensees on Uyghur Forced Labor

The WRC has sent an update to university licensees to ensure awareness of important additions to the list of companies in China whose products are effectively banned from the US market—because the US government has determined that these companies are implicated in the forced labor of Uyghurs. We are writing to let you know about this communication to licensees.
 
The key additions to the US government’s “Entity List” are major producers of cotton yarn—Huafu Fashion Co. and numerous subsidiaries. University labor standards, and US law, bar the importation of any product that includes content from these companies, which means licensees must ensure that none of their suppliers are using yarn from Huafu Fashion or the relevant subsidiaries.
 
We do not know of any licensee that is sourcing from any company on the Entity List, and none of the banned companies appear in the factory disclosure data that licensees supply. However, it is important for licensees to be vigilant, and it is important to note that most licensees do not include suppliers of yarn (or cotton or fabric) in their disclosure. Many also do not track these inputs systematically across their supply chains.
 
As our update to licensees advises, the most important preventative measure licensees can take is to ensure that their clothing suppliers understand that they must not use any company from the US government Entity List as a source of cotton, yarn, or fabric.

The WRC asked university licensees to cut ties with companies implicated in Uyghur forced labor beginning in 2020—even before these companies were barred by US law. We continue to closely monitor developments on Uyghur forced labor, and we continue to support strong enforcement of US laws that bar forced labor-made goods. This is crucial to ensuring that apparel bearing university names and logos is free of forced labor content.
 
You can read the communication to licensees below and here. As always, please let us know if you have any questions.

July 25, 2025

Dear University Licensee,

I am writing to advise you of the recent placement of a sizeable number of yarn producers on the list of companies whose products are legally prohibited from entry into the United States, due to a determination by the US government that they are associated with Uyghur forced labor in China. This has implications for the sourcing of university logo apparel.

As described in our July 2020 guidance concerning the steps necessary for licensees to comply with university labor standards with respect to the forced labor crisis in the Xinjiang Uyghur Autonomous Region (“Uyghur Region”), the government of China has been perpetrating human rights abuses on a massive scale targeting Uyghurs and other Turkic and Muslim-majority peoples on the basis of their ethnic and religious identity. State-imposed forced labor in the Uyghur Region involves three primary mechanisms: forced labor of internment camp detainees, forced labor transfers in and outside of the region, and forced prison labor. Because of extreme levels of repression and surveillance, Uyghur workers are not able to speak freely about the conditions they are facing without risking harsh retaliation from the authorities. Therefore, labor rights audits are a practical impossibility in this context. You may find my Congressional testimony on this topic useful as background.

As you know, in June 2022, the Uyghur Forced Labor Prevention Act (UFLPA) came into force, establishing a rebuttable presumption that any goods produced wholly, or in part, in the Uyghur Region, or in facilities elsewhere in China receiving labor transfers from the region, are made with forced labor and therefore prohibited from entry into the US under Section 307 of the Tariff Act of 1930. As part of the UFLPA’s enforcement, the interagency Forced Labor Enforcement Task Force (FLETF), chaired by the Department of Homeland Security, is charged with maintaining a consolidated register of companies that the FLETF has determined to be implicated in the use of Uyghur forced labor. It is called the UFLPA Entity List. Customs and Border Protection uses the list to prevent the importation of goods produced in whole or in part by these companies.

As noted in our guidance for university licensees, Huafu Fashion Co., one of the world’s largest manufacturer and supplier of dyed yarn, is enmeshed in the Chinese government’s forced labor apparatus in the Uyghur Region. Therefore, we advised licensees to immediately end any relationships with the firm for the production of collegiate goods.

One important subsidiary of Huafu Fashion Co. was included on the US government’s original Entity list. This year the FLETF has added 25 corporate entities that are part of the Huafu conglomerate to the list.

Below are the names of these entities, which include production facilities, as well as entities involved in other aspects of the yarn business. For reference, you will also find below a list of all other cotton, textile, apparel, and footwear companies on the Entity List.

While no university licensee is currently disclosing any company on the Entity List as a supplier of university logo product, many of these companies are involved in the production or processing of raw material and/or yarn and would not necessarily appear in a licensee’s disclosure unless that licensee has a policy to include suppliers at those levels of the supply chain. It is therefore important, as the US government continually expands the Entity List, that you make sure your suppliers of finished collegiate products are not using inputs from any company on the list—including companies added recently or in the future. As you know, both US law and university codes of conduct prohibit the importation of products made in whole or in part with forced labor. It is important to note this prohibition applies to all licensees, whether or not they have a direct sourcing relationship with the factories where their clothes are produced.

Please let me know if you have questions.

Sincerely,

Scott Nova
Executive Director
Worker Rights Consortium

Huafu Fashion Co. and its subsidiaries, as listed on the UFLPA Entity List
Huafu Fashion Co., Ltd.
Aksu Huafu Color Spinning Co., Ltd. (also known as Aksu Huafu Textiles Co., Ltd.*; Akesu Huafu*; Aksu Huafu Dyed Melange Yarn*; and Akesu Huafu Melange Yarn Co., Ltd.)
Aksu Biaoxin Fiber Co., Ltd. (formerly known as Aksu Shangheng Fiber Co., Ltd.)
Awati Huafu Textile Co., Ltd.
Huyanghe Huafu Hongsheng Cotton Industry Co., Ltd.
Kuche Zongheng Cotton Industry Co., Ltd.
Kuitun Jinfu Textile Co., Ltd.
Ningbo Huafu Donghao Industrial Co., Ltd.
Ninghai Huafu Textile Co., Ltd.
Shaya Yinhua Cotton Industry Co., Ltd.
Shihezi Huafu Hongfeng Cotton Industry Co., Ltd.
Shihezi Huafu Hongsheng Cotton Industry Co., Ltd.
Shihezi Standard Fiber Co., Ltd.
Xinjiang Cotton Industry Group Jiashi Cotton Industry Co., Ltd.
Xinjiang Cotton Industry Group Yuepu Lake Cotton Industry Co., Ltd.
Xinjiang Huafu Color Spinning Group Co., Ltd.
Xinjiang Huafu Cotton Industry Group Co., Ltd.
Xinjiang Huafu Hengfeng Cotton Industry Co., Ltd
Xinjiang Huafu Hongfeng Agricultural Development Co., Ltd.
Xinjiang Huafu Textile Co., Ltd.
Xinjiang Liufu Textile Industrial Park Co., Ltd.
Xinjiang Shengfu Cotton Industry Co., Ltd.
Xinjiang Tianfu Cotton Supply Chain Co., Ltd.
Xinjiang Tianhong Xinba Cotton Industry Co., Ltd. (also known as Xinjiang Tianhong New Eight Cotton Industry Co., Ltd.)
Xinjiang Zefu Cotton Co., Ltd.
Zhejiang Weixin Trading Co., Ltd.
 
Other cotton, textile, apparel, and footwear facilities on the UFLPA Entity List
Anhui Xinya New Materials Co., Ltd. (formerly known as Chaohu Youngor Color Spinning Technology Co., Ltd.; and Chaohu Xinya Color Spinning Technology Co., Ltd.)
Baoding LYSZD Trade and Business Co., Ltd.*
Binzhou Chinatex Yintai Industrial Co., Ltd.
Changji Esquel Textile Co., Ltd. (also known as Changji Yida Textile Co., Ltd.)*
China Cotton Group Henan Logistics Park Co., Ltd., Xinye Branch
China Cotton Group Nangong Hongtai Cotton Co., Ltd.
China Cotton Group Shandong Logistics Park Co., Ltd.
China Cotton Group Xinjiang Cotton Co.
Dongguan Oasis Shoes Co., Ltd. (also known as Dongguan Oasis Shoe Industry Co. Ltd.; Dongguan Luzhou Shoes Co., Ltd.; and Dongguan Lvzhou Shoes Co., Ltd.)
Esquel Group (also known as Esquel China Holdings Limited)
Fujian Minlong Warehousing Co., Ltd.
Guangdong Esquel Textile Co., Ltd.
Henan Yumian Group Industrial Co., Ltd.
Henan Yumian Logistics Co., Ltd. (formerly known as 841 Cotton Transfer Warehouse)
Hengshui Cotton and Linen Corporation Reserve Library
Hetian Taida Apparel Co., Ltd (and one alias: Hetian TEDA Garment)*
Heze Cotton and Linen Co., Ltd.
Heze Cotton and Linen Economic and Trade Development Corporation (also known as Heze Cotton and Linen Trading Development General Company)
Huangmei Xiaochi Yinfeng Cotton (formerly known as Hubei Provincial Cotton Corporation’s Xiaochi Transfer Reserve)
Hubei Jingtian Cotton Industry Group Co., Ltd.
Hubei Qirun Investment Development Co., Ltd.
Hubei Yinfeng Cotton Co., Ltd.
Hubei Yinfeng Warehousing and Logistics Co., Ltd.
Jiangsu Yinhai Nongjiale Storage Co., Ltd.
Jiangsu Yinlong Warehousing and Logistics Co., Ltd.
Jiangyin Lianyun Co. Ltd. (also known as Jiangyin Intermodal Transport Co. and Jiangyin United Transport Co.)
Jiangyin Xiefeng Cotton and Linen Co., Ltd.
Juye Cotton and Linen Station of the Heze Cotton and Linen Corporation
Linxi County Fangpei Cotton Buying and Selling Co., Ltd.
Nanjing Synergy Textiles Co., Ltd. (including two aliases: Nanjing Xinyi Cotton Textile Printing and Dyeing; and Nanjing Xinyi Cotton Textile)*
Nanyang Hongmian Logistics Co., Ltd. (also known as Nanyang Red Cotton Logistics Co., Ltd.)
Turpan Esquel Textile Co., Ltd.
Wugang Zhongchang Logistics Co., Ltd.
Xinjiang Junggar Cotton and Linen Co., Ltd.*
Xinjiang Production and Construction Corps (including three aliases: XPCC; Xinjiang Corps; and Bingtuan) and its subordinate and affiliated entities*
Xinjiang Tianmian Foundation Textile Co., Ltd.
Xinjiang Tianshan Wool Textile Co. Ltd.
Xinjiang Yinlong Agricultural International Cooperation Co.
Xinjiang Zhongtai Chemical Co. Ltd.
Xinjiang Zhongtai Group Co. Ltd
Yili Zhuowan Garment Manufacturing Co., Ltd.*

* Facilities present on the list since its original release in June 2022.