---
title: CBP Asked for Chinese Factory Information? | China Agent
description: CBP asked for information about your Chinese factory? The records to pull from China, how to organize them for the response, and what never to invent.
image: https://www.china-agent.com/hubfs/palletized-cartons-ready-for-container-loading-china.jpg
---

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# CBP Asked for Chinese Factory Information. What Do You Send?

![Shrink-wrapped pallets of cartons staged beside a trailer before container loading in China](https://www.china-agent.com/hubfs/palletized-cartons-ready-for-container-loading-china.jpg)

- September 24, 2026

![Eldad Shashua](https://www.china-agent.com/hubfs/Eldad%20Shashua.jpeg)

[Eldad Shashua](https://www.china-agent.com/blog/author/eldad-shashua)

CBP asked for information about your Chinese factory. What do you send? Send records that already exist: the factory’s Chinese legal name and business license, the purchase orders, invoices and packing lists for this shipment, proof of who you paid, the shipping papers, and any dated production or visit records. Every Chinese page gets an English translation, and the whole thing goes in as one indexed package. Your customs broker handles the filing, and your trade lawyer or counsel decides what the response says. Don’t write new letters or rebuild the story after the fact.

This is manageable. CBP asks because it has to keep goods made with forced labor out of the US, catch origins that aren’t what the paperwork says, and keep things fair for importers who play straight. Its own guidance says compliant importers share that goal. The records it wants are the ones a working factory already keeps. The job is getting them out of the factory, in order, in the time you have.

The scramble goes like this. The letter or the broker’s email lands. Someone opens WeChat. Last year’s English PDFs sit in one folder. The Chinese licenses, the payment proofs and the production papers that would actually answer the question are still in the factory’s cabinets and in chats nobody read. The clock is running, and people start rewriting a story that should have been collected during production.

## Who does what when CBP asks?

Four roles get mixed up when this happens:

1. **You, the importer of record.** You carry reasonable care under [19 U.S.C. § 1484](https://www.govinfo.gov/content/pkg/USCODE-2023-title19/html/USCODE-2023-title19-chap4-subtitleIII-partIII-sec1484.htm). You certify the entry, and the commercial decisions are yours.
2. **Your customs broker.** Your broker handles the filing and the entry with CBP.
3. **Your trade lawyer or counsel.** Counsel decides what the response says, how it is framed and what the legal strategy is.
4. **China Agent.** We get the China-side papers from the supplier or factory you already have, verify them, have them translated and organize the file: named companies, addresses, payment match, and production and visit records where they exist. Gaps stay visible.

If anyone promises to “clear CBP” or “stop the detention,” walk away. CBP’s own [Reasonable Care](https://www.cbp.gov/document/publications/reasonable-care) publication puts the duty on the importer of record. Good evidence supports your response. It is not a release stamp.

## What does CBP mean by Chinese factory information?

The question can arrive as a CBP Form 28 request for information (a [CF-28](https://www.china-agent.com/cf-28-response-china)), a detention notice, a list from your broker, a retailer audit, or an internal review after someone read about forced labor. The exact form matters for counsel. The China-side homework looks much the same.

CBP’s June 2026 [Forced Labor Enforcement Operational Guidance for Importers](https://www.cbp.gov/document/guidance/cbp-forced-labor-enforcement-operational-guidance-importers) and its [UFLPA enforcement FAQs](https://www.cbp.gov/trade/forced-labor/faqs-uflpa-enforcement) point to documents produced in the ordinary course of business: who made and moved each step, how money and goods changed hands, and how those pieces map to the finished shipment. CBP asks for an English translation of every foreign-language document, next to the original.

Here is that, turned into a working pack for an importer who already has a Chinese supplier. It isn’t legal advice. It’s the China-side file the people handling your response can actually use.

### 1. Party and role map

- Chinese legal name of the seller (from the business license), Unified Social Credit Code, registered address, legal representative, status
- Operating / factory address if different from the registered address
- Plain statement of role: manufacturer, trader, packer or exporter, and how the parties relate
- If the invoice party is a trader: the named manufacturing factory, with its own license identity when you have it

English storefront names and Alibaba shop titles do not replace Chinese legal names.

### 2. Transaction records for this shipment (or this SKU run)

- Purchase orders / contracts with chop
- Commercial invoices
- Packing lists
- Specs or work orders that match the goods on the water
- Change orders if anything shifted mid-run

Dated. Matching the goods. Not a generic brochure PDF from last year.

### 3. Payment identity

- PI / wire instructions
- Bank remittance proofs showing who was paid
- A clear note on whether the beneficiary name matches the licensed entity on the contract

A PI without a matching payee trail is a story with a hole in it. Put the hole on the page. Do not paper over it with a new PDF written after the ask arrived.

### 4. Physical movement

- Bills of lading, waybills, booking docs
- Warehouse or transfer notes when inputs or finished goods moved between named entities
- Packing or export paperwork that shows who handled the box

Financial proof alone is thin when the question is where manufacture and material physically sat.

### 5. Production / capacity / visit trail (when you have it)

- Production photos with dates
- Capacity or production records the factory already generates
- Visit notes: who went, when, where, who sat down, what was seen, what was refused
- Certificates you actually verified against the product, not a folder of unopened PDFs

If nobody has ever stood in the building, say that. Inventing a visit after the letter arrives is worse than an honest gap.

### 6. Upstream / input layer (when product risk needs it)

Where forced labor or origin risk sits on your product, counsel will ask about key inputs. Ordinary-course invoices, contracts and movement records for those inputs matter more than a one-line “not Xinjiang” email. For forced labor reviews, CBP’s June 2026 guidance says that missing production information for even one supplier in the chain makes the submission insufficient. Ask your trade lawyer or counsel what your product needs, and don’t invent an upstream story you can’t support.

### 7. English and index

- English translations of the Chinese pages that matter
- A simple index: document → party → role → shipment link
- A one-page cover note for your broker: what you have, what is still open, who on the China side is chasing what

CBP’s [Best Practices for Applicability Reviews](https://www.cbp.gov/document/guidance/best-practices-applicability-reviews-importer-responsibilities) ask for a clear, complete package with English translations, and describe executive summaries that list each stage, each supplier and its documents. CBP reviews the documents as a package, not piecemeal. An unsorted WeChat dump wastes the time you have.

For a plain-English list of the papers importers get asked to produce from the factory side, see [10 things CBP will ask you to produce](https://www.china-agent.com/blog/10-things-cbp-will-ask-you-to-produce). For the UFLPA pack built around those papers, see [UFLPA China documentation pack](https://www.china-agent.com/blog/uflpa-china-documentation-pack).

## What should you never send or invent?

**A fresh affidavit with no trail.** One signed letter saying “we comply” and “we make everything in-house,” written after the request arrived, with no purchase orders, invoices, payments or production records behind it. CBP’s forced labor guidance says affidavits on their own are not sufficient for an applicability or exception review.

**Only the trading company.** Polished English PDFs from the company that invoiced you, while the factory that cut, molded or assembled the goods never shows up with a license, an address or a production record.

**Photos with no date, no address and no names.** Nice pictures of a workshop that could be anyone’s. A visit note needs who, when and where.

**A rewritten PI that suddenly matches the license after the money already went to a different name.** Fix it going forward with counsel. Don’t fake the past.

**Anything you can’t explain if CBP or counsel asks how you got it.** Reasonable care is a process you can describe. It is not a collage.

## What do you do in the first days?

1. **Forward the request the same day.** Send it to your broker, who handles the filing, and to your trade lawyer or counsel, who advises on the response. Don’t write your own reply to CBP from WhatsApp.
2. **Pull what already exists.** License scans, PIs, payment proofs, packing lists, bills of lading, WeChat threads that name addresses and promises, and any earlier visit reports.
3. **Name the gaps out loud.** Missing manufacturer identity. Missing upstream records. Missing English. Missing proof that the payee matches the license. A file with known gaps is still a file.
4. **Ask China for the records the factory already keeps, not a new marketing pack.** Dated, chopped and matching the goods. Some suppliers worry about showing their prices or their own suppliers. CBP’s best practices note that a supplier may be willing to give those documents directly to CBP, so ask.
5. **Organize it for the people who file.** Index, roles, translations, cover note. Then stop adding stories.
6. **Decide the supplier question separately.** If a supplier won’t share production information for a step you need, that is a supplier decision for you. Your trade lawyer or counsel can tell you what it means for this entry.

Our job in this window is the China side. We go to the supplier face to face, introduce ourselves as working for you, and sit down with the people who can decide. Most suppliers are good and will help once someone explains why it matters. Some can’t, and it’s better to find that out now than on the next order. We write down what we got and what was refused. Your broker still files. You still certify.

## How do you get ready before the next request?

The expensive version of this article is the one you read while the request is already on your desk. The cheaper version is built while production happens. Neither one is free, but one of them comes with a deadline.

That is what [Monthly Support](https://www.china-agent.com/monthly-support-packages) is for. We go to your factories, read everything they send in Chinese, follow up on missing documents, watch for changes in the company name or the bank account, and keep the China-side record current across orders. When a CF-28 or a detention notice lands, the records already exist. Visibility is $995 a month plus a $1,000 setup fee, for up to three suppliers.

If you want one person in China full time on your instructions, collecting the papers as production happens, look at [Employee in China](https://www.china-agent.com/employee-in-china). It’s your person, employed properly under Chinese law through our hubs, legally registered in each city, and working only for you. From $595 a month plus the salary and costs paid out in China, with a 10% handling fee on those, and setup from $1,800.

If a supplier only hands over papers when chased, write it into the contract. A [Contract Manufacturing Agreement](https://www.china-agent.com/contracts) under Chinese law includes raw material traceability clauses, so the records become part of the deal. It costs $2,650.

If you’re not sure who the company really is, start with a [$95 Supplier Reality Check](https://www.china-agent.com/supplier-reality-check). It shows the license, who owns the company and what other companies they’re tied to, the registered address, lawsuits and the bank account, in writing within two business days.

## Already holding a CBP request?

Send us the supplier names, the SKU, what was asked for and whatever China papers you already have. We’ll tell you what the China side can and can’t support in the time you have. If the goods are already held, our [CBP Documentation Rescue](https://www.china-agent.com/cbp-documentation-rescue) gets the factory records at one fixed price, $4,995. [Book a free 30-minute call](https://www.china-agent.com/booking) or message us on [WhatsApp at +86 153 2208 6875](https://wa.me/8615322086875). We work for you, the importer. We don’t file entries, give legal advice or get anyone through CBP.

---

## Frequently asked questions

### What should I send when CBP asks for Chinese factory information?

Send records that already exist, organized as one package. That means a map of the parties with each company’s Chinese legal name, the purchase orders, invoices and packing lists for the shipment, payment proofs that show who was paid, shipping records, and any dated production or visit records. CBP’s forced labor guidance asks for documents produced in the ordinary course of business, with an English translation of every foreign-language document. Your customs broker handles the filing, and your trade lawyer or counsel decides what the response says.

### Can China Agent reply to CBP for me?

No. China Agent gets, verifies, translates and organizes the China-side records from your supplier or factory. Your customs broker handles the filing, you remain the importer of record, and your trade lawyer or counsel advises on the response. China Agent does not file entries, does not give legal advice and cannot promise any CBP outcome.

### Is a supplier letter saying “we make everything in-house” enough?

No, not on its own. CBP’s Forced Labor Enforcement Operational Guidance for Importers says documents like affidavits are not sufficient for an applicability or exception review. CBP looks for ordinary-course records of the transactions, payments, production and movement of the goods. A supplier letter can sit on top of those records, but it can’t replace them.

### What if my supplier is a trading company, not the factory?

Buying from a trading company is legal, but the file has to name the factory that made the goods. Put the trading company on the file, name the manufacturer with its own business license, and gather records from both when the request covers manufacture and inputs. Presenting the trading company as the manufacturer is what breaks a file.

### How long do I have to respond to a UFLPA detention?

30 days. Under CBP’s Best Practices for Applicability Reviews, the importer has 30 days to address a detention, either by exporting the goods or by providing documentation to contest it. If more time is needed, the importer can ask for an extension by emailing the point of contact on the detention notice before the 30 days run out.

### Will this pack get my goods released?

No one can promise that. CBP decides release and admissibility. A complete, organized package of real records gives the people handling your response something solid to work with, and CBP says it reviews documents as a package, not piecemeal.

### How does Monthly Support help before CBP asks?

Monthly Support keeps the China-side records building while orders move, so the next request doesn’t start from zero. China Agent visits your factories, reads what suppliers send in Chinese, follows up on missing documents and flags changes in a supplier’s company name or bank account. The Visibility plan is $995 a month plus a $1,000 setup fee, for up to three suppliers with one factory visit a month.

None of this is legal advice. For questions about your own entry or your response to CBP, talk to your trade lawyer or counsel.

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: November 2, 2026

 Blog Post

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