UFLPA Entity List Adds BGI Group, BGI Genomics and MGI Tech, Putting Sequencing Imports Under Forced-Labor Presumption

Gene sequencers, reagents and lab services from three of China's best-known genomics companies now face a presumptive ban at the U.S. border. The Department of Homeland Security added BGI Genomics Co., Ltd., MGI Tech Co., Ltd. and Shenzhen BGI Technology Co., Ltd. to the Uyghur Forced Labor Prevention Act Entity List, which means U.S. Customs and Border Protection will treat goods those companies make as products of forced labor unless an importer proves otherwise. Reuters reported the move on Oct. 28, and DHS published the updated list in the Federal Register on Oct. 29, 2026.

The notice, FR Doc. 2026-22094 at 91 FR 68159, supersedes the version of the list published Aug. 3, 2026 (91 FR 48913). With the three additions, DHS says the consolidated list now contains 190 entities. The government identifies Shenzhen BGI Technology as the company also known as BGI Group and BGI Holdings.

For federal contractors and subcontractors that buy sequencing instruments, consumables or testing services, the change turns a supplier-diligence question into a customs question. Shipments tied to these firms can be held at entry, and the burden of rebutting the presumption falls on the importer.

Why DHS Says BGI and MGI Belong on the UFLPA List

DHS acted as chair of the Forced Labor Enforcement Task Force (FLETF), the interagency body that maintains the list. All three companies landed on the list kept under section 2(d)(2)(B)(ii) of the UFLPA, which covers entities working with the government of the Xinjiang Uyghur Autonomous Region (XUAR) "to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of" the region.

The notice ties each company to genetic testing in Xinjiang. For BGI Genomics and BGI Group, the FLETF said the government has reason to believe the firms conduct genetic testing in the XUAR alongside the regional government and as part of its government initiatives. For MGI, an instrument and reagent maker, the case centers on equipment and capacity. The notice states: "The United States Government has reasonable cause to believe, based on specific and articulable information, that MGI has provisioned genetic testing capacity to the XUAR government to conduct genetic testing in the XUAR including as a part of its government initiatives."

Two of the three firms, BGI Genomics and BGI Group, also went onto a second sub-list under section 2(d)(2)(B)(v), which covers entities that source material from Xinjiang or from people working with the regional government or the Xinjiang Production and Construction Corps for labor programs. The notice says BGI Genomics conducts genetic testing "including on genetic material of plants, animals, and bacterial diseases sourced from the XUAR", and that BGI Group conducts testing "including on genetic material of human beings sourced from the XUAR."

The notice also describes the companies' business lines. BGI Genomics provides research services, precision medicine testing and health management services. MGI focuses on "instruments, reagents, and related products in the field of life science and biotechnology." BGI Group develops sequencing technologies and built and manages the China National GeneBank. DHS says Shenzhen BGI Technology is BGI Genomics' controlling shareholder, and that MGI sits under the same ultimate controlling shareholder.

How the Forced-Labor Presumption Works at the Border

Since June 21, 2022, the UFLPA has required the CBP Commissioner to apply a rebuttable presumption that goods "mined, produced, or manufactured" by listed entities are made with forced labor and barred from entry under 19 U.S.C. 1307. The presumption reaches products made wholly or in part by a listed company, not only finished goods carrying its brand.

Reuters summarized the effect plainly: "US Customs and Border Protection is instructed to stop goods from companies on the list from entering the US unless exporters can rebut the presumption they were made with forced labor." The wire service noted that goods affected by the list overall range "from cotton and canned tomatoes to electronics."

The process for getting on and off the list runs through the FLETF. Any member agency can recommend an addition, and member agencies decide by majority vote. Members include DHS, the Office of the U.S. Trade Representative, and the Departments of Labor, State, Justice, the Treasury and Commerce. A listed entity can petition the FLETF Chair for removal with information showing it no longer meets, or never met, the criteria, and can request a meeting with the task force. The removal decision also comes by majority vote and is not appealable, though the FLETF will consider a new request backed by new information.

What MGI Tech Said, and the US-China Trade Backdrop

MGI Tech rejected the allegations. Reuters reported that the Shenzhen-based company called them inconsistent with the facts and said its U.S. business represents a limited part of its overall operations. "We have zero tolerance for forced labor in any form," the company said in a statement.

BGI Genomics and BGI Group did not immediately respond to Reuters' requests for comment. Reuters noted that BGI Group has previously denied participating in the collection, storage or analysis of personal genetic information to infringe on human rights, and has denied supporting surveillance of minorities.

The listing landed during what Reuters described as a fragile trade truce between Washington and Beijing. Genomics equipment has already been a pressure point: Reuters recalled that China banned imports of sequencing equipment from San Diego-based Illumina in March 2025, and that Illumina said in November 2025 that China's Ministry of Commerce would lift the ban while keeping the company on its Unreliable Entities List.

What It Means for Contractors

Companies that support federal research, public health, defense medical and laboratory programs should treat the Oct. 29 list as the current baseline and screen against it now. Practical steps include:

Re-screen suppliers and distributors. Check sequencers, reagent kits, consumables and service contracts against all three names and their aliases, including BGI Group, BGI Holdings and MGI.
Trace components, not just brands. The presumption covers goods made "wholly or in part" by a listed entity. Ask lab-equipment vendors whether any subassemblies or reagents originate with these firms.
Plan for delays and substitutes. If a program depends on BGI- or MGI-made instruments or consumables, line up alternative sources before inbound shipments sit at the port.
Flow the requirement down. Prime contractors should push updated screening to subcontractors and ask for written confirmation, since a lower-tier import problem can still stall delivery on the prime contract.
Watch for further updates. DHS says future additions, removals and technical corrections will appear on its UFLPA page and in new Federal Register notices.

The list is not exhaustive, the notice cautions, so a clean screen does not end a supplier's diligence obligations. It does, however, give contracting teams three specific names to clear out of life-science supply chains this quarter.