News Desk
A popular toy has become an unlikely symbol in a much larger American debate over Chinese supply chains, forced labour and the limits of import enforcement. Labubu dolls, the rabbit-eared collectable toys that became a global consumer sensation, have been drawn into scrutiny over allegations that some products contain cotton originating from China’s Xinjiang region.
At the same time, a bipartisan group of US lawmakers is pressing the Department of Homeland Security (DHS) to explain how effectively Washington is preventing goods linked to forced labour from reaching American consumers. The pressure comes weeks after DHS made its largest single expansion of the Uyghur Forced Labour Prevention Act (UFLPA) Entity List, adding 43 companies and bringing the list to 187 entities.
The additions took effect on August 3, with US Customs and Border Protection (CBP) applying the law’s rebuttable presumption to goods produced by the newly listed entities.
The developments have shifted attention from the existence of the US forced-labour import ban to a harder question: how effectively can authorities trace products through increasingly complicated international supply chains?
On September 3, eight lawmakers from both parties sent a letter to DHS Secretary Markwayne Mullin requesting a briefing on implementation and enforcement of the UFLPA. The group included House Select Committee on China Chairman John Moolenaar, Congressional-Executive Commission on China co-chair Chris Smith, Democratic committee member Ro Khanna, Senator Jeff Merkley, Jim McGovern, Bennie Thompson, Young Kim and Carlos Gimenez.
The lawmakers asked DHS to provide information on what CBP is stopping at the border, what is being released and how quickly additional companies are being considered for the UFLPA Entity List. They also sought information about goods whose components originate in China but are processed or assembled in third countries.
Their questions extend beyond textiles. They cover sectors including steel, aluminium, critical minerals, silicon-carbon materials and seafood, reflecting the widening range of products that can contain raw materials or components associated with Xinjiang. The letter also asks how DHS is using artificial intelligence to assess country-of-origin information and supply-chain documentation, and how the United States is working with other governments to address transshipment through third countries.
The UFLPA was enacted in December 2021 and became operational in June 2022.
It created a rebuttable presumption that goods mined, produced or manufactured wholly or partly in Xinjiang, or by entities identified on the UFLPA Entity List, were made with forced labour and are prohibited from entering the United States unless the statutory requirements for overcoming the presumption are met. CBP leads enforcement of that presumption.
The system does not depend solely on identifying finished products made in Xinjiang.
The Entity List covers several categories of companies, including entities involved in labour-transfer programmes and businesses sourcing material from Xinjiang or from organisations involved in government labour schemes.
The August expansion demonstrated how broad the enforcement framework has become.
DHS added four entities under one category involving recruitment or transfer of workers and 41 under another category involving Xinjiang-sourced materials or government-linked labour programmes.
The Federal Register notice also makes clear that the Entity List is not intended to be an exhaustive catalogue of every entity potentially involved in practices covered by the law. That distinction is important because enforcement must often move beyond the name appearing on an import document.
The UFLPA is not merely a paper restriction. In its 2025 strategy update, DHS said CBP had examined more than 16,000 shipments valued at almost $3.7 billion since implementation of the law’s rebuttable presumption. CBP’s enforcement framework allows the agency to detain, exclude and, where applicable, seize and forfeit shipments that fall within the scope of forced-labour restrictions.
The agency has also developed a system through which companies and other parties can provide information relating to suspected forced labour, UFLPA applicability reviews and exceptions.
CBP says such information can be used to investigate supply-chain allegations and determine whether merchandise should be allowed into the country. But the lawmakers’ September letter focuses on whether enforcement is keeping pace with the complexity of the trade networks it is designed to police.
A product arriving at an American port may not reveal the origin of every material used to manufacture it. Raw cotton can move between processors. Metals can pass through several manufacturers.
Components can be assembled in one country before being incorporated into a finished product somewhere else. Documentation can show the immediate exporter without fully revealing the origin of upstream inputs.
The September 3 congressional request specifically asks DHS how it is identifying Chinese inputs that move through other countries before reaching the United States. The lawmakers also asked about cooperation with foreign governments to reduce diversion and transhipment. The issue is particularly significant for Xinjiang because the UFLPA applies not only to finished products directly exported from the region but also to merchandise containing material covered by the statute.
DHS has previously acknowledged the importance of supply-chain tracing.
Its 2024 UFLPA strategy said agencies can use information from Congress, civil society, businesses, academic research and media reports when identifying potential entities, while government analysts independently assess and verify evidence where possible.
The controversy surrounding Labubu has brought the supply-chain question into the consumer market.
The New York Times reported in April that testing of 20 Labubu dolls purchased from multiple retailers found Xinjiang-origin cotton in clothing attached to some of the toys. The results were independently confirmed by the newspaper, according to a statement published by Representative Chris Smith’s office.
A separate account of the testing said 16 of the 20 dolls examined contained cotton traced to Xinjiang. The testing concerned the geographic origin of cotton and did not by itself establish that the specific cotton in every tested product was produced with forced labour. That distinction is central to any UFLPA investigation. Geographic origin and proof of forced labour are related but are not interchangeable findings. The congressional letter nevertheless cited the Labubu case while asking DHS how it handles goods potentially connected to Xinjiang supply chains.
Labubu’s scrutiny has also extended beyond the source of cotton. China Labor Watch reported in January that it had interviewed 51 workers and reviewed employment and workplace documents at Shunjia Toys in Jiangxi Province, a major manufacturer producing Labubu toys for Pop Mart.
The organisation said the factory employed more than 4,500 workers and alleged excessive overtime, wage deductions, irregular contracts, extensive use of dispatched labour and deficiencies in workplace protections. China Labour Watch has subsequently characterised some of the findings as potentially relevant to a forced-labour assessment, while stressing that evidence of serious labour-law violations is not automatically proof of forced labour. The organisation said it had submitted additional evidence to CBP.
No public CBP announcement has established a Labubu-specific UFLPA enforcement action.
The distinction remains significant. Allegations concerning working conditions at a particular factory, evidence concerning the geographic origin of cotton and a formal government finding under the UFLPA represent different stages of an investigation.
The September letter reflects a broader concern about whether the enforcement machinery can keep pace with evolving supply chains. Lawmakers have asked DHS for sector-by-sector and country-by-country shipment outcomes, information about staffing devoted to UFLPA enforcement, details about the evidence importers must provide to overcome the statutory presumption and information about newer supply chains involving critical minerals and battery materials.
They also want information about the pace at which companies are being added to the Entity List and about DHS efforts to investigate forced-labour violations and trade-related crimes. The questions come shortly after the 43-company expansion, which DHS described as the largest single increase in the Entity List since its creation. The agency said the additions brought the total number of listed entities to 187.
For lawmakers, the issue is no longer simply whether the United States has a legal mechanism to block forced-labour goods. The focus has moved towards how that mechanism performs when materials cross several borders, when supply chains involve multiple layers of subcontractors and when the finished product bears little visible connection to the source of its raw materials. The September request puts DHS under scrutiny over precisely that gap between legislation and traceability. As American consumers continue to buy products manufactured through complex global networks, the enforcement question increasingly begins long before a container reaches a US port.
