U.S. Customs enforcement data and isotopic cotton testing reveal that despite years of corporate promises, fast fashion supply chains remain deeply entangled with Xinjiang’s forced labor apparatus — and the brands marketing themselves as socially conscious are the worst offenders.
The Testing Reveals the Truth
In November 2025, Bloomberg’s isotopic testing of 42 garments bound for the U.S. market produced a stunning result: 90% tested positive for cotton signatures consistent with Xinjiang origin. The garments came from brands that publicly pledged to eliminate forced labor from their supply chains. The cotton in their products told a different story.
The Uyghur Forced Labor Prevention Act, signed in December 2021, created a rebuttable presumption that all goods from Xinjiang are produced with forced labor. Customs and Border Protection was empowered to seize imports that couldn’t prove otherwise. By November 2025, the UFLPA Entity List had grown to 144 entities, with 78 new additions in 2025 alone.
The Shein Problem
Shein — the Chinese-founded fast fashion giant with projected 2025 revenue of $38 billion — remains conspicuously absent from the UFLPA Entity List despite mounting evidence of supply chain contamination. The Fashion Law Journal has documented how the company exploits the de minimis shipping loophole, sending individual packages valued under $800 directly to consumers — bypassing the customs inspection processes that would flag UFLPA violations in bulk shipments.
Shein claims that only 1.3% of its cotton came from “unapproved regions” in 2024. BBC investigations have found that Shein suppliers’ workers face 75-hour work weeks in violation of Chinese labor laws. Texas Attorney General Ken Paxton has opened an investigation into the company for forced labor reliance, unsafe materials, and deceptive marketing.
The Enforcement Gap
The Forced Labor Enforcement Task Force has identified apparel, cotton products, silica-based products, tomatoes, red dates, vinyl, aluminum, steel, batteries, copper, electronics, and tires as high-risk sectors for Xinjiang forced labor contamination. CBP has issued Withhold Release Orders on cotton products from the region. But enforcement operates at the port of entry — and the sheer volume of imports, combined with the de minimis loophole, means that a fraction of contaminated goods are actually intercepted.
The brands that market themselves as socially conscious — that feature diverse models, that publish sustainability reports, that pledge solidarity with human rights causes — are selling clothes made with cotton picked by Uyghur forced labor. The isotopic tests don’t lie. The supply chains haven’t been cleaned. And the holiday shopping season keeps the demand pipeline flowing.
Eduardo Bacci is an investigative journalist at The Investigative Journal. Data sources include CBP forced labor enforcement data, Bloomberg isotopic testing, and DHS UFLPA strategy updates.