--- title: 10 Things CBP Will Ask You to Produce. Not Your Supplier description: "CBP asks you, not your supplier, for records kept in the factory: the maker's license, raw material records, a bill of materials, labor files and more." image: https://www.china-agent.com/hubfs/crated-furniture-loading-china-factory.jpg --- [Skip to content](https://www.china-agent.com/blog/10-things-cbp-will-ask-you-to-produce#main-content) [![China Agent](https://www.china-agent.com/hs-fs/hubfs/china-agent-180-1.png?width=60&height=60&name=china-agent-180-1.png "China Agent")](https://www.china-agent.com/) - [Home](https://www.china-agent.com) - [About Us](https://www.china-agent.com/about-us) - [Case Files](https://www.china-agent.com/case-files) - Monthly Support - [China Supplier Control](https://www.china-agent.com/monthly-support-packages) - [Your own employee in China](https://www.china-agent.com/employee-in-china) - Fixed-Price Services - [Supplier Reality Check ($95)](https://www.china-agent.com/supplier-reality-check) - [Due Diligence](https://www.china-agent.com/due-diligence) - [Contracts](https://www.china-agent.com/contracts) - [Guided Visits](https://www.china-agent.com/guided-visits) - [Fixer](https://www.china-agent.com/fixer) - [Blog](https://www.china-agent.com/blog) - [Contact Us](https://www.china-agent.com/contact-us) - [Book a call](https://www.china-agent.com/booking) - [Or WhatsApp us](https://wa.me/8615322086875) # 10 Things CBP Will Ask You to Produce. Not Your Supplier ![Crated and boxed furniture waiting at the loading bay of a factory in China](https://www.china-agent.com/hubfs/crated-furniture-loading-china-factory.jpg) - September 21, 2026 ![Eldad Shashua](https://www.china-agent.com/hubfs/Eldad%20Shashua.jpeg) [Eldad Shashua](https://www.china-agent.com/blog/author/eldad-shashua) ## CBP may ask you for these. They sit with your supplier, and most suppliers will help. It's manageable: the things CBP will ask you to produce are records about who made your goods, from what, and who got paid, and for a good supplier most of them already exist. They include the maker's business license, raw material purchase records, a bill of materials, labor records and your entry documents. When CBP has questions, it writes to you, the importer of record, not to your factory. The documents sit in your supplier's factory, in a filing cabinet, in Chinese. Reasonable care is your duty, not your supplier's, but the evidence that shows it sits with them. Collecting it while things are calm is far easier than asking for it under a deadline. Why CBP asks: the rules exist to keep forced labor out of the products people buy, to stop goods being routed through a third country to hide where they were made, and to make sure honest factories aren't undercut by ones that cut corners. The result is better, safer products. Most suppliers are glad to show they work that way once someone explains what's needed and why. Here are the ten things CBP will ask *you* to produce. Ask your supplier for them now, politely, and explain why. Most will help. --- ## 1. Is the company on my invoice the company that made my goods? You may not be sure. The name on the invoice can be a trading company, with the goods made by a factory it sub-contracts to, sometimes more than one. CBP's question is about the manufacturer, not the commercial relationship. You need the business license of the entity that physically produced the goods: legal name in Chinese, unified social credit code, registered address, scope of business. Not a letterhead. The license. Most suppliers will show you the license of the actual production factory once you explain why you need it. If one won't, that tells you where to look next. If you want a second pair of eyes on the license you're given, our [$95 Supplier Reality Check](https://www.china-agent.com/supplier-reality-check) verifies the license, owner, registered address and business scope in two business days. ## 2. Where did the raw material come from? Origin isn't decided at the loading dock. It's decided upstream: at the mill, the smelter, the yarn spinner, the resin producer. CBP wants proof of raw material origin: purchase records between your factory and its own suppliers (the tier you've probably never spoken to), plus a manufacturer's affidavit naming the entity and the specific place each material was mined, smelted, spun or grown. These records sit with your factory. It may hesitate, because they show its own cost base. That's a conversation, best had face to face, and far easier before there's a problem than during a detention. ## 3. Can I produce a bill of materials that matches my HS code? Classification drives your duty rate, your AD/CVD exposure, and your enforcement risk. It rests on what the product is actually made of and how, not on what the invoice calls it. CBP asks *you* for this. Your factory is the only place the real answer exists. A bill of materials mapped to the tariff classification is the document that connects the two. Ask for it by **country**, not by supplier nickname: where was the fabric woven, the resin polymerized, the component molded. Your factory may never have been asked in that format. It has a production sheet, in Chinese, written for the production line, not for customs. Back it with what the factory can actually show: mill certificates, material lab reports, and a manufacturing process flowchart (cut, mold, assemble, finish) that matches what you're claiming happened. Translating a production sheet into a defensible BOM is work. Do it once, before entry, and it holds for every shipment after. ## 4. Are my supplier's certificates worth anything? On their own, not much. CBP doesn't accept generic certificates as proof of compliance. Self-issued documents from a supplier (the signed declaration, the compliance letter, the certificate with the company chop) carry little weight, because the supplier wrote them about itself. What carries weight is traceable, verifiable documentation: government-issued licenses, transaction records, third-party verification, physical evidence tied to a date and a place. A supplier affidavit still has a place. It just works best with the records behind it. ## 5. Does "we are not in Xinjiang" protect me? Not on its own. Under UFLPA there's a rebuttable presumption against goods from Xinjiang. But CBP looks upstream, not just at your factory's postcode. A factory in Zhejiang buying cotton, polysilicon or aluminum from a Xinjiang-linked supplier can still be caught by it, and so can you. Geography is the first question, not the last. The answer that matters is the supply map: who supplies your supplier, and where they buy, traced with transport and logistics records showing where the raw material actually moved from, not where the paperwork says it started. ## 6. Who pays if the goods turn out to be subject to AD/CVD? The importer does. Antidumping and countervailing duties are the importer's liability, not the supplier's. Rates can be high (the government's July 2026 guide notes some cases above 600 percent), and they can apply after the goods are sold. Your supplier is best placed to know whether the product sits in a covered scope. Ask, in writing and in Chinese, and put the answer in the contract as a warranty. ## 7. Is my country-of-origin marking actually correct? Every article of foreign origin must be marked in a conspicuous place, as legibly, indelibly and permanently as the article permits, with the English name of the country of origin. Three places this fails. The mark must give the English country name, "Made in China", not Chinese characters, a city or a supplier logo. The exceptions are narrow. And "we'll add it at packing" is where it can go wrong. Get the marking *method* from the factory in writing before production (laser etch, mold-in, stamp or label), not just a photo after the fact. A method that can be swapped at packing is not a method CBP will find convincing. Ask for a photograph of the marking on a real production unit and on the retail packaging, before the container is sealed. Not on the sample. On production. ## 8. Can I produce labor records from my factory? This is the hardest item on the list, and the one that needs the most care with your supplier. Worker records, wage payment and output per worker, recruitment practices and fee receipts, dormitory logs, and a grievance mechanism workers can actually use: that's what forced-labor enforcement turns on. A factory that has never been asked about labor may take the request as an accusation at first. Explained face to face, with the reason behind it, most good factories come around. It lands very differently from a Chinese-speaking person sitting in the office, over tea, than from an email sent from Ohio. ## 9. What happens when the letter actually arrives? A CF-28 is CBP asking you to prove what you already declared. It isn't an accusation. It's a question with a deadline, printed on the letter and running from CBP's date, not the day you opened the email. The letter itself is manageable. What makes it hard is timing: the evidence is in a Chinese factory, the factory may be on holiday, and the person who knows the answer may have left. Everything on this list exists to make that week boring. Assemble it while the relationship is good: a supplier asked during an open order, with the reason explained, is much easier to work with than one asked about a shipment from last year. If a letter is already on your desk, start with our [CBP Form 28 and CF-29 page](https://www.china-agent.com/cf-28-response-china). ## 10. Who is my importer of record, really? If your supplier sells you DDP and arranges the broker, there are two gaps to know about. You can't see what was declared (undervaluation and misclassification can hide in those channels), and you have no entry records to substantiate anything when CBP asks. CBP penalties follow the goods and the beneficial owner. That's you, whatever the paperwork says. Where you can, be the importer of record. At minimum, ask for the entry summary and supporting documents for every shipment. A good supplier will understand why. --- ## What this list isn't This is what lives inside the factory. Your classification memo, your customs bond, your power of attorney, your IPR recordation, your [Form 5106](https://www.china-agent.com/blog/supplier-importer-of-record-form-5106): those live with your broker and your counsel, and we don't touch them. We go to the factory for the other half: the license, the mill, the wires, the worker records, the production line. ### The pattern Every item on this list is a document that exists, today, inside a building in China. None of it can be produced from a desk in the United States. Some of it you can ask for yourself, politely, with the reason explained. The deeper records, like tier-two names and labor files, usually come after a face-to-face conversation. It isn't free and it isn't a factory rebuild: for a good supplier it's mostly documents that already exist, collected, matched and kept current. We set out how those records fit together in [Prove Who Made Your Goods in China](https://www.china-agent.com/blog/prove-who-made-your-goods-in-china). Our team sits with your supplier, reads the license and photographs the line. We write [the contract in Chinese, under Chinese law](https://www.china-agent.com/contracts), with the correct entity and the correct chop, so handing these documents over is something your supplier agreed to up front, not a favor you ask for later. What we collect goes into a [Reasonable Care File](https://www.china-agent.com/reasonable-care-file) for each supplier, and the file is yours to keep. Who makes your goods can change after the first order, so the file can't be a one-off. [Monthly Support](https://www.china-agent.com/monthly-support-packages) puts our people on the suppliers you already use, with a factory visit every month and your file kept current as orders ship. Want to know which of the ten your supplier can already produce? [Book a 30-minute call](https://www.china-agent.com/booking) or WhatsApp us at [+86 153 2208 6875](https://wa.me/8615322086875). ## Questions people ask ### Is the company on my invoice the company that made my goods? Not always. The name on the invoice can be a trading company that sub-contracts production. CBP's question is about the manufacturer, so you need the business license of the entity that physically produced the goods. ### Are my Chinese supplier's certificates enough for CBP? Not on their own. Self-issued supplier documents carry little weight, because the supplier wrote them about itself. Traceable records carry more: government-issued licenses, transaction records and third-party verification tied to a date and a place. ### Does buying from a factory outside Xinjiang protect me under UFLPA? Not on its own. UFLPA creates a rebuttable presumption against goods from Xinjiang, and CBP looks upstream. A factory elsewhere in China buying cotton, polysilicon or aluminum from a Xinjiang-linked supplier can still be caught by it, and so can you. ### Who pays antidumping and countervailing duties? The importer, not the supplier. These duties can apply after the goods are sold, so settle the scope question in writing before the first order and put the answer in the contract as a warranty. ### What is a CF-28? A CF-28 is a CBP Request for Information asking you to support what you declared, by the date printed on the letter. The evidence sits with your supplier in China, so it is easier to collect before a letter arrives. ### Should my supplier be my importer of record? Where you can, be the importer of record yourself. If your supplier sells you DDP and arranges the broker, you can't see what was declared and you have no entry records when CBP asks. At minimum, ask for the entry summary and supporting documents for every shipment. ### What labor records can CBP ask about? Worker records, wage payment and output per worker, recruitment practices and fee receipts, dormitory logs, and a grievance mechanism workers can actually use. A factory that hasn't been asked before may hesitate, and the request lands best face to face. None of this is legal advice. Your customs broker or trade lawyer is the right call for that. China Agent has worked on the client side in China since 2009. Today it is a Hong Kong company with people in Guangzhou, Foshan, Yiwu, Shenzhen and Jinan. Last updated: 20 October 2026 No sourcing, no commissions. We work for one side: yours. Blog Post ## Related Articles   [![Banded plywood panel bundles loaded in a container with Made in Vietnam labels](https://www.china-agent.com/hubfs/plywood-panels-loaded-container-.jpg)](https://www.china-agent.com/blog/china-supplier-raw-materials-origin) [Knowledge Hub](https://www.china-agent.com/blog/tag/knowledge-hub) ### [What should you ask a Chinese supplier about raw materials and origin?](https://www.china-agent.com/blog/china-supplier-raw-materials-origin) September 26, 2026 Ask for names and paper, not promises. For every key input in your order you want the Chinese legal entity that sold... 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[Read more](https://www.china-agent.com/blog/subcontractors-china-production-chain) [![](https://www.china-agent.com/hubfs/supplier-importer-of-record-form-5106.jpg)](https://www.china-agent.com/blog/supplier-importer-of-record-form-5106) ### [If Your Supplier Is the Importer of Record, Form 5106 Is Your Problem](https://www.china-agent.com/blog/supplier-importer-of-record-form-5106) August 22, 2026 If your supplier is the importer of record on your US entries, or you buy DDP and have never asked who is, the Form... [Read more](https://www.china-agent.com/blog/supplier-importer-of-record-form-5106) [Check all articles](https://www.china-agent.com/blog) be ready when CBP asks ### See how Monthly Support keeps this file current, every month ###### Our management team on your China supplier file. Every month. 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Today it is a Hong Kong company with people in Guangzhou, Foshan, Yiwu, Shenzhen and Jinan.", "founder" : { "@id" : "https://www.china-agent.com/the-eldad-method#eldad-shashua", "@type" : "Person", "name" : "Eldad Shashua", "sameAs" : "https://www.linkedin.com/in/eldad-shashua-36519040/" }, "foundingDate" : "2009", "legalName" : "China Agent Ltd", "logo" : "https://www.china-agent.com/hubfs/ChinaAgent%20Logo%20Design%20PNG-2.png", "name" : "China Agent", "sameAs" : [ "https://www.linkedin.com/company/guangzhou-agent/" ], "url" : "https://www.china-agent.com/" } ``` ```json { "@context" : "https://schema.org", "@type" : "FAQPage", "mainEntity" : [ { "@type" : "Question", "acceptedAnswer" : { "@type" : "Answer", "text" : "Not always. The name on the invoice can be a trading company that sub-contracts production. 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