UFLPA Forced-Labor Traceability
- Tier-1 to tier-3 input mapping for cotton, polysilicon, tomato, aluminum
- Worker-recruitment and wage records reconciled against payroll
- Xinjiang-nexus screening of subcontractors and raw-material sources
For US Importers
UFLPA, Section 301 and FDA evidence — captured at your Chinese factory.
CBP detains shipments. Brokers don't catch it. We do — on the ground in China, before the container leaves the port. Forensic supplier files built for US importers, customs brokers and compliance counsel.
Why US buyers are exposed
A clean PO doesn't survive a CBP detention.
UFLPA reverses the burden of proof: every Chinese-origin shipment is presumed to contain forced-labor inputs unless you prove otherwise. CBP is detaining electronics, apparel, solar, and auto parts — and a supplier letter is not enough evidence.
Section 301 tariff engineering also collapses if the substantial-transformation claim cannot be defended at the factory. We see relabeled cartons, fake country-of-origin marks, and tier-2 inputs that never appear on the BOM.
Procubility builds a defensible US importer file: UFLPA traceability, FDA / FCC / CPSC dossier checks, and a chain-of-custody walk from raw input to the carton you ship.
What we cover for US importers
Four risk tracks audited in one factory visit.
Section 301 / Country-of-Origin
- Substantial-transformation claim verified at the production line
- Carton, marking and HTS code cross-checked against actual SKU
- Transshipment-risk screening (Vietnam / Cambodia / Mexico relabeling)
FDA / FCC / CPSC Dossier
- DoC, FCC ID, and FDA registration validity checked at source
- Lab reports cross-referenced to the actual SKU shipped
- CPSC children's-product testing and tracking-label compliance
Sanctions & Entity-List Screening
- Supplier and parent-company AIC screening against US entity lists
- Beneficial-ownership check on bank-account recipients
- Sub-tier exposure to UFLPA Entity List producers
What you get
A US importer file your customs broker and counsel can defend.
CBP-Defensible Evidence
Primary records, geotagged photos, and worker interviews — built to survive a CBP detention review.
UFLPA Traceability Map
Tier-1 to tier-3 input lineage with Xinjiang-nexus screening at every step.
Tariff-Risk Findings
Country-of-origin and substantial-transformation evidence for Section 301 defense.
One Visit, One File
UFLPA, FDA, FCC, CPSC and sanctions evidence captured in the same audit cycle.
Free download
The US Importer's China Audit Checklist.
What CBP, FDA, FCC, and CPSC actually expect from your Chinese supplier file — in one 25-point audit-ready checklist.