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
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.