How to screen a Vietnamese supplier against the UFLPA Entity List
A check you can run yourself, what to do with a match, and why a clean result is only the start.
The short answer. Collect every name connected to the supplier: its legal names, former names, owners, parent company and material suppliers. Search each one, and each alias, on the Entity List page of the US Department of Homeland Security (DHS). Write down the date you searched and the date the list was last updated. If a name matches or nearly matches, stop and clarify before you order. A clean result does not clear the goods, because the US presumption also reaches products made with inputs from the Xinjiang region.
What is the UFLPA Entity List?
The Uyghur Forced Labor Prevention Act (UFLPA) lets US Customs and Border Protection (CBP) presume that goods made with forced labour are not allowed into the United States. The Entity List names companies whose goods are subject to that presumption. DHS publishes it at dhs.gov/uflpa-entity-list.
The list is split into sections by the reason a company was added. One section covers entities in Xinjiang that mine, produce or manufacture goods wholly or in part. Another covers entities that work with the Xinjiang government to recruit and move workers. A third covers facilities that source through government labour programmes. Each entry shows a name, any aliases ("also known as", "formerly known as") and an effective date. It does not show addresses or registration numbers.
DHS does not state a schedule for updates. On 3 August 2026 DHS added 43 companies at once, which brought it to 187 entities. The page shows when it was last updated, and that date belongs in your record.
Why screen a Vietnamese supplier?
Goods made by a listed company are subject to the presumption. CBP also says that any goods made with any inputs from Xinjiang are presumed to be made with forced labour, including a small input several steps up the chain. A Vietnamese factory can be clean itself and still buy from, or be owned by, a company that is not. Screening the supplier alone leaves out most of that chain.
Step by step
- Collect the names. Ask the supplier for its full legal name in Vietnamese and English, any former names, its owners and parent company, and the companies that supply its main materials and parts. Add names from the business registry (see our due diligence checklist).
- Search each name on the DHS page. The page is a set of tables, so the find function of your browser works. Search by the full name, then by a shorter form, then by each word that is not generic.
- Search the aliases and spellings. Names are often spelled in more than one way. Try the transliteration variants, abbreviations and the order of words. Check whether a listed name appears as an alias of another entry.
- Check owners and parents. A supplier that is not listed may belong to a group that is. Search the owners, the parent and any affiliate that shares the address.
- Rule out look-alikes. The list has no addresses or registration numbers, so a name match does not prove it is the same company, and a missing match does not prove it is not. Compare what you have: registered address, owners, products, the group structure.
- Record the result. Keep a dated record of what you searched and what you found.
- Repeat. Search again at every new order, and whenever the list changes.
What to put in the screening record
| Field | Example |
|---|---|
| Date of search | 13 October 2026 |
| List last updated | Date shown on the DHS page that day |
| Names searched | Legal name, former names, owners, parent, material suppliers |
| Result for each name | No match, near match, or match, with the entry that was compared |
| How a near match was resolved | Registry extract, owner list or the supplier's written explanation |
| Who checked | Name of the person |
| Source | Link to the DHS page, or the Federal Register notice for the list version |
What if you find a match or a near match?
Do not place or confirm the order until it is clear. Ask the supplier in writing for its ownership structure and for an explanation of the match. Compare what it tells you with the business registry. If the match is real, or you cannot rule it out, take advice from your legal counsel before you decide. This page is general information and not legal advice.
What screening cannot tell you
- The list is not the whole risk. Products can be caught because of Xinjiang inputs even when no listed company is involved. Screening needs to go with tracing the inputs. Our guide on UFLPA and transshipment risk in Vietnam explains what CBP asks for.
- A name search is not a visit. It does not show whether the factory exists, what it buys or whether part of the work is done in another workshop.
- A list is a snapshot. A supplier that was clean last month may not be clean after the next update.
Common questions
Is there a free UFLPA Entity List search? DHS publishes the list on its website and in the Federal Register. The DHS page is a set of tables, and your browser's find function searches it. There is no search form with fuzzy matching, so try several spellings.
Does a clean result mean the supplier is cleared? No. It means no match was found for the names you searched on that date. The presumption also applies to goods made with Xinjiang inputs, so the supply chain still needs to be traced.
How often should I screen? At every new supplier, at every new order, and whenever the list is updated. The list can change at short notice.
Who is responsible for the screening? The importer. CBP expects importers to know their supply chains and to be ready to respond to its questions.
Related
- UFLPA and transshipment risk in Vietnam
- One evidence file for EUDR, UFLPA and the Lacey Act
- Vietnam supplier due diligence checklist
Official sources: DHS, UFLPA Entity List · CBP, UFLPA enforcement FAQs. General information, not legal advice.
We run this screening for you. The Field Diligence Preliminary Check (USD 500) includes sanctions and Entity List screening of the supplier, checked against the business registry. A Compliance Verification adds the site visit, where we check ownership, inputs and subcontracting on the ground. It is paid by you and never by the supplier. See current pricing or book a free scoping call.