What reasonable care records should a China importer keep? Keep a file that shows who made your goods, under which Chinese company, at which address, who you paid, and what you did to confirm it, with dates. In practice that means the supplier’s Chinese business license, the factory address, proof that the bank account belongs to the same company, dated visit notes, and the purchase orders, invoices and shipping papers you already have. Under CBP’s recordkeeping rule, records tied to an entry are generally kept for five years from the date of entry.
This is manageable. Reasonable care is your duty as the importer of record. Your broker files the entry and your supplier can email certificates, but neither one carries that duty for you. A working factory already has most of what the file needs. It sits there in Chinese. The job is getting it out, matching it to your orders and keeping it current.
The mistake to avoid is treating a Gold Supplier badge, a WhatsApp chat or a one-day QC report as the whole story. Those things can be useful. They don’t tell you who the company is, and they aren’t a dated file you can open when the question arrives.
Stop collecting “compliance documents” as a pile. Build a file that answers one sentence: who made these goods, under which Chinese company, at which place, and what did I do to confirm it?
At minimum, keep:
A marketplace badge is one input. A supplier affidavit is one input. Neither one is the factory. The file has to connect those papers to a real company and, when it matters, to a real production site.
Under 19 U.S.C. § 1484, the importer of record must use reasonable care when making entry, giving CBP the information it needs to assess duties, collect accurate statistics and decide whether other legal requirements are met. CBP’s Reasonable Care Informed Compliance publication explains that duty in trade language. A broker helps. The duty stays with you.
For a China importer, that turns into plain, concrete work:
Whether you answer for something a supplier told you, and how far, depends on the facts: what you knew, what you asked and what went on the entry. That’s a question for your trade lawyer or counsel. And if anyone offers to “clear CBP” or “stop the detention” for you, walk away.
| Party | Owns | Does not own |
|---|---|---|
| You (importer of record) | Reasonable care; certifying the entry; commercial decisions | Expecting a vendor to “clear CBP” for you |
| Customs broker | Filing the entry; Form 5106 with you | Visits to the factory that makes your goods; legal advice |
| Trade lawyer or counsel | Customs and UFLPA legal questions; what a response to CBP says | Day-to-day WeChat and chop work in China |
| China Agent | Supplier records; contracts; factory visits; monthly follow-up; Employee in China | Finding factories; commissions; filing entries; legal advice; CBP outcomes |
If someone sells you “compliance” as a stamp for your cargo, walk away. What you want is a China-side file that shows someone actually went to the factory and asked.
A polished English pack can look fine: ISO certificates, a factory profile, photos of a workshop that could be anyone’s. Then the license name doesn’t match the PI. Or the bank account belongs to a different person. Or the “factory” address is a trading company, and the goods are made somewhere nobody on your side has ever named.
Reasonable care for a China importer is a process you can describe later. You identified the company, you tested who gets paid, you asked where production happens, you wrote down the answer, and when the stakes were high enough you put a person at that door. A feeling that the supplier seems honest doesn’t count.
Where subcontractors, packing sites, or raw materials matter for your product and your risk, the file also needs room for those questions. One generic declaration that “we do not use forced labor” does not map a supply chain. Keep the open gaps visible. A yellow file with named holes is still a file. A clean PDF that hides the holes is not.
The rules behind this exist for good reasons. CBP has to keep goods made with forced labor out of the US and catch origins that aren’t what the paperwork says, and honest factories shouldn’t be undercut by ones that cut corners. CBP’s June 2026 Forced Labor Enforcement Operational Guidance for Importers ties reasonable care under § 1484 to the forced labor laws: verify supplier practices, keep traceability of goods back to the raw material stage, and be prepared to show the goods weren’t made wholly or in part with forced labor. Its UFLPA FAQs point to documents produced in the ordinary course of business. On affidavits the guidance is plain: on their own, they are not sufficient for an applicability or exception review.
Before you argue about unit price, open the Chinese business license.
You want the Chinese legal name, the 18-digit Unified Social Credit Code (USCC / 统一社会信用代码), the legal representative, the registered address, and the status. Then look up that same USCC on China’s public National Enterprise Credit Information Publicity System, usually called GSXT (gsxt.gov.cn).
Match three places to the same party:
If those three names don’t match, stop. English marketing names don’t count. A Hong Kong trading company with a similar English brand isn’t automatically the mainland factory. If the public record shows the company as dissolved or revoked, don’t pay until you know why.
We do this paper work as a fixed job, the $95 Supplier Reality Check, in writing within two business days. It doesn’t replace a factory visit. It stops you wiring money to a ghost before lunch.
Paper answers “is this company real and is the payee the same company?” It does not answer “is this the place making my goods?”
When someone visits the factory for you, the file should show:
A visit isn’t a product inspection, and it isn’t a release stamp. It’s a dated record of who we met, what we saw and what was missing. Most suppliers are good and open up once someone sits down with them and explains why it matters. Some can’t. If a supplier won’t let anyone in, that refusal stays on the page, and it’s far better to learn it before the order than at the port.
Keep the visit report with the commercial and import records. When your broker needs it for an entry, or your trade lawyer or counsel asks what you did on the China side, it’s already there. It supports your file. CBP still makes its own decision.
Buying from a trader is legal. Calling a trader a factory is how files die. When the invoice party is a trader, put the trader on the file and name the manufacturing factory. Visit the actual factory that makes your goods when the stakes call for it. Keep both entities. Your file should answer “supplier vs manufacturer” before anyone else asks.
Build the file while production happens. Do not rebuild it after a detention notice.
Keep these as ordinary business records. When any of them go to CBP, CBP’s forced labor guidance asks for an English translation of every foreign-language document, next to the original:
CBP’s forced labor guidance lists these same kinds of records, from purchase orders and bills of materials to payment and shipping records, because real businesses already produce them. A one-page supplier affidavit with no trail behind it is what people write when they never kept the trail.
Keep them for five years. CBP’s recordkeeping regulation, 19 C.F.R. § 163.4, says a record that relates to an entry is kept for five years from the date of entry, with a few exceptions such as drawback claims.
We chase and organize the China-side pieces, in Chinese, with the people at the factory who hold them.
A one-time PDF dump answers yesterday’s email. The chain moves. A new subcontractor, a new bank account, a new company chop, and the pack you thought you had is out of date. That’s why we build it as a Reasonable Care File: one file per supplier, built with the supplier in their factory, kept current and owned by you. Starting with one supplier costs $1,195: our $795 in-person factory visit plus the $400 CBP Evidence Score.
Monthly Support keeps the file alive. 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 record up to date across orders. It starts at $995 a month plus a $1,000 setup fee, with the Visibility plan, for up to three suppliers. You keep the commercial relationship and make every decision.
If you want one person in China full time on your instructions, collecting the papers as production happens, look at 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.
Send us the supplier name, the SKU, the latest PI, the payment details and whatever packing or production papers you already have. We’ll tell you what the China side can and can’t support. Book a free 30-minute call or message us on WhatsApp at +86 153 2208 6875. We work for you, the importer, and take no factory commission. We don’t file entries, give legal advice or get anyone through CBP.
A dated file that shows who made the goods, under which Chinese legal entity, at which address, who was paid and what the importer did to confirm it. That means the supplier’s business license and Unified Social Credit Code, whether the supplier is the factory or a trading company, a payment match, purchase orders, invoices, packing lists, shipping records, and dated visit notes. A trade lawyer or counsel can say what a specific product and entry require.
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, and CBP asks for documents produced in the ordinary course of business. A badge or an affidavit can be one input in the file, tied to a real company and, when it matters, a real factory.
The customs broker files the entry. The importer of record carries reasonable care under 19 U.S.C. § 1484 and certifies what goes on the entry. China Agent gets, verifies and organizes the China-side records from the supplier or factory. Legal questions about an entry go to a trade lawyer or counsel.
Five years from the date of entry, in general. CBP’s recordkeeping regulation, 19 C.F.R. § 163.4, sets five years for records that relate to an entry, with exceptions such as records for drawback claims.
No. A factory visit gives the importer’s file a dated record of who was met, what was seen and what was missing. CBP decides release and admissibility, and no one can promise an outcome. A good record means the file is ready for the next notice.
A one-time report is a snapshot, and Monthly Support keeps the file current across orders. China Agent visits the 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.
No. The importer brings the supplier. China Agent verifies and documents the supplier or factory the importer already chose, takes no factory commission and does not act as a middleman.
None of this is legal advice. For questions about your own entries, 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 3, 2026