On July 31, 2026, the U.S. Department of Homeland Security announced the largest expansion of the Uyghur Forced Labor Prevention Act Entity List to date, adding 43 companies and bringing the total to 187. 

The additions took effect on August 3, extending the UFLPA rebuttable presumption to goods produced wholly or in part by those entities. Days later, China’s Ministry of Commerce placed six U.S. organizations, including the Responsible Business Alliance (RBA), on a countermeasure list, and prohibited organizations and individuals in China from conducting relevant transactions or cooperating with them.

The Responsible Minerals Initiative (RMI) was not separately named, but it is an initiative of the RBA. That connection has raised understandable questions for companies that use RMI reporting templates and Responsible Minerals Assurance Process (RMAP) data. The RBA has since stated that the countermeasures apply to entities and individuals operating within China and that its operations outside China are unaffected. 

There is no basis at this stage to treat Conflict Minerals Reporting Template (CMRT) or Extended Minerals Reporting Template (EMRT) collection as prohibited for all Chinese suppliers, or to invalidate existing RMAP determinations. The more immediate concern is information access: Chinese suppliers, smelters, refiners, or auditors may become more cautious about providing data or participating in RBA-linked activities.

Companies should continue their due diligence. They should also prepare for a world where audit participation and supplier responses can change for reasons that do not, by themselves, establish a responsible sourcing violation. Programs built on several independent risk signals will be better equipped to make that distinction.

Two Policy Directions Are Increasing Information Risk

The UFLPA creates a rebuttable presumption that goods mined, produced, or manufactured wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, cannot be imported into the United States unless the importer satisfies the applicable requirements. The words “wholly or in part” matter. A listed upstream producer can create risk even when a direct supplier is not listed, or when the relevant material or component passes through another country before entering the United States in a finished product.

China, meanwhile, expanded its supply chain and extraterritorial countermeasure framework in April 2026. State Council Decree 834 established a framework for assessing conduct that China determines may harm its industrial and supply chain security. Implementing procedures published by the Ministry of Commerce in June authorize investigations using document requests, questionnaires, hearings, technical assessments, and on-site work. State Council Decree 835 strengthened China’s response to foreign measures it considers an improper exercise of extraterritorial jurisdiction.

The August 5 countermeasure decision made the operational tension more concrete. U.S. authorities expect importers to understand upstream production, while some Chinese counterparties may see certain investigations, requests, or partnerships as legally or commercially sensitive. Manufacturers should not respond by suspending outreach. They should request the objective facts needed for their risk assessment, document genuine disclosure constraints, and escalate supply chains where visibility is not enough.

Audit Status Is Valuable but Cannot Carry the Whole Program

Independent third-party audits remain an important part of mineral due diligence. RMAP evaluates smelter and refiner management systems and sourcing practices against OECD-aligned requirements, and its status data helps downstream companies prioritize their work. But an audit status is a point-in-time indicator with a defined scope. It does not replace a company’s responsibility to consider geography, sanctions, credible allegations, supplier data quality, or new events after an assessment.

Assent’s Smelter Risk Scoring was designed around that broader view. It evaluates three factors together:

• Geographic risk: Whether the mineral originated in or moved through the Democratic Republic of the Congo (DRC) and adjoining countries, another conflict-affected and high-risk area (CAHRA), or a location associated with plausible production, export, or transit risk.
• Audit status: Whether or not the facility is conformant while also considering applicable cross-recognized programs such as the London Bullion Market Association’s Good Delivery Program and the Responsible Jewellery Council Chain of Custody Certification.
• Sourcing risk: Credible third-party evidence and public company filings that may indicate sanctions exposure, human rights concerns, unethical conduct, or sourcing connected to conflict areas.

This matters in the current environment because a change in audit participation is only one signal. A facility may pause or reconsider participation because of legal uncertainty, yet still require review based on geography or credible sourcing information. A conformant status should not end the inquiry when other red flags emerge. A program that retains all three lenses can continue to prioritize risk even when one source of information becomes less available.

How Assent Supports Concerned Clients

Assent reviews the language used in supplier engagement so that requests focus on the information manufacturers need rather than ask suppliers to adopt a legal conclusion. These changes do not reduce the importance of recognized reporting templates or audit information. Outreach should remain focused on objective information such as manufacturing location, material origin, upstream supplier identity, processor or smelter details, and chain-of-custody evidence. Assent’s regulatory experts are also available to help customers interpret supplier responses, distinguish legal restrictions from ordinary non-response, and decide where enhanced review is warranted.

A Strong Program Can Adapt Without Losing Its Purpose

The U.S. and Chinese actions should be read together. The United States is increasing scrutiny of upstream Chinese supply chains while China is strengthening tools that may discourage or constrain some forms of foreign-driven investigation and cooperation. The resulting challenge is not simply whether a supplier is responsive. It is whether the manufacturer can assemble enough reliable evidence to understand risk and support an import or sourcing decision.

Audit programs remain valuable, but they are most effective inside a due diligence system that also assesses geography, credible sourcing-risk information, supplier declarations, and changes over time. That is the foundation of Assent’s minerals solutions and why they remain effective when the regulatory environment changes. You get the product intelligence, centralized in a system of record and action, that ensures you always have the most up-to-date insights into your compliance status.

Learn about Assent’s conflict minerals solution or book a demo today.