--- title: "UFLPA Detention: Documents CBP Wants | China Agent Ltd" description: CBP detained your shipment under UFLPA. You have 30 days. The proof is in a Chinese factory, not in a certificate. What is happening, what to do today. --- [Skip to content](https://www.china-agent.com/uflpa-detention-documentation#main-content) [![china-agent-180-1](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-180-1")](https://www.china-agent.com/?hsLang=en) - [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?hsLang=en) - [Or WhatsApp us](https://wa.me/8615322086875) UFLPA HOLD ON A SHIPMENT FROM CHINA # CBP detained your shipment under UFLPA. You have 30 days, and the proof is in a factory in China. ###### CBP is presuming that goods tied to Xinjiang, or to a company on the UFLPA Entity List, were made with forced labor. Anywhere in the chain, down to the raw material. ###### You have to prove otherwise, with records, on a clock. A letter from your supplier saying "no forced labor" is not that proof. ###### Here is what is happening, what to do today, and what the file has to contain. Then, if you want it, what we do.   *We are not US trade counsel. A court already ruled that trusting your broker or your factory doesn't count as reasonable care. That duty is yours, not theirs. We get the China-side file. Your broker and counsel submit it.* [Book a 30-min call →](https://www.china-agent.com/booking?hsLang=en) [or WhatsApp us](https://wa.me/8615322086875) ## What just happened to my shipment? ###### Under the Uyghur Forced Labor Prevention Act (Public Law 117-78, enforced under 19 U.S.C. §1307), CBP does not have to prove your goods were made with forced labor. It presumes they were, if any input connects to the Xinjiang region or to a listed entity. The burden is yours to rebut. That is the whole law in one sentence. ###### Look at the notice. It will be one of three things, and they are not the same: A UFLPA detention. The goods are held. You can submit evidence, or you can export them. Most China importers reading this page are here. A Withhold Release Order (WRO). CBP has reasonable suspicion about a specific producer or product. Same choice: prove admissibility or export. A Finding. CBP has probable cause. This is seizure, not detention. You cannot re-export. The goods are forfeit unless you petition and win. The notice tells you which. If you can't tell, that is the first thing to settle today. The clocks and the outcomes are different. Source: DOJ/DHS Trade Fraud Guide, July 2026, pp.15–16; CBP Forced Labor Enforcement Operational Guidance for Importers, June 2026, pp.26–31. ## How long do I have? From the date on the notice, not the date you read it: | Action | Time to respond | Then what | | --- | --- | --- | | UFLPA detention (potential input) | **30 days** | Up to two 30-day extensions, maximum 90. At the Port Director's discretion, not yours | | UFLPA (direct input from a listed entity) | 180 days | Exclusion | | WRO | 3 months | Export or forfeit | | Finding | **30 days** | Seizure. Petition or lose the goods | | Redelivery demand | 30 days | Liquidated damages against your bond | Two things the table doesn't say. You are paying storage at the port for every one of those days. And the extension is a request, not a right. A director grants it, and nothing about a stranger's file makes them want to. Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, summary table pp.36–37, p.38. Storage: CBP UFLPA Enforcement FAQs (cbp.gov). ## What should I do today? ######  In this order. None of it costs anything.  ### 1. Read the notice properly. Which authority: UFLPA, WRO, Finding. Which port. The entry number. The name and contact of the CBP officer on it. Write those four things down; every conversation from here starts with them. ### 2. Contact the CBP officer named on the notice. Before your broker, before your lawyer, before us. CBP's own guidance to importers says to open that dialogue immediately. A file with no contact on the CBP side is a file nobody is reading yet. ### 3. Tell your customs broker and, if you have one, your trade counsel. They will file the response. They cannot collect it. They have never been in the building. ### 4. Get your supplier's legal Chinese name and the factory address. Today. Not the trading company on the invoice. The entity whose name is on the business license at the place where the goods were made. If you don't know it, that is the first gap in your file. ### 5. Do not let the factory write to CBP. And do not send the "no forced labor" certificate the factory offers you. It is the document that dies first, and it tells the reviewer you don't know what they're asking for. ### 6. Decide, within days, which fight you're in. See the next section. The file is different. ## Which fight am I in: applicability review or exception? ######  Two routes. Pick wrong and you build the wrong file.  ### Applicability review. You argue UFLPA doesn't apply to these goods: nothing in the chain touched Xinjiang, nothing was made by a listed entity. You prove it with the supply-chain file described below. This is where most China importers actually are. ### Exception. You accept UFLPA may apply and argue the goods still weren't made with forced labor. The standard is clear and convincing evidence, the highest bar in civil law. And if CBP grants one, it must report it to Congress within 30 days and publish the details. That tells you how often it happens. [Book a 30-min call →](https://www.china-agent.com/booking?hsLang=en) ## What does CBP actually want to see? ###### Ordinary business records. Not a story. CBP's June 2026 guidance lists them in Appendix E, and they come down to five things: **A map of every step, and who did each.** Cotton to yarn to fabric to garment. Bauxite to billet to extrusion to frame. Which company, at which address, did what. **Where every material came from.** A certificate or a signed manufacturer's affidavit for each input, naming the entity and the specific place it was mined, smelted, spun or grown. Not "China." The mill. **The money and the paper at every tier.** Purchase orders, invoices, packing lists, payments, shipping records. For your supplier's suppliers, not only for you. **Production records that tie input to output.** Production orders, capacity, and (CBP names these specifically) factory site-visit reports and evidence that the volume of material going in matches the goods coming out. **Proof of how you know who tier two is.** For every company you never dealt with directly, the business record that told you they exist. Then the sentence that decides most files. From Appendix B of the same guidance: if you cannot provide production information on even a single supplier in the chain, the submission is insufficient and the shipment is denied. Not weakened. Denied. We have watched a five-tier file die on the sixth name: a small parts supplier nobody thought mattered. Why it's hard: those records sit with companies that have never met you, in Chinese, held by people with no reason to release them. An email from a foreign buyer asking a tier-two supplier to sign an affidavit naming its smelter gets a polite nothing. The factory's own paperwork protects the factory. Nobody in that chain is paid to hand you their supplier's name. *Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, Appendix E pp.56–57; Appendix B pp.49–50.* ## What doesn't work? ######  We see the same six things offered, and fail, in almost every detention:  **The supplier's "no forced labor" letter.** Self-issued. Zero weight. **The audit binder.** BSCI, ISO, a financial audit, an environmental audit. CBP's guidance says none of these count. It wants an unannounced audit, by an independent third party, against the ILO's eleven indicators of forced labor. Your factory is proud of the binder. It isn't the document. **An Entity List screen on your direct supplier only.** CBP asks about inputs. The list is checked against tier two and three, not just the name on your PO. **"We ship from Vietnam."** A third-country invoice is not a clean chain. If the material or a listed entity sits behind it, the hold stands. **A certificate with no factory behind it.** Chop from a company that isn't on the PI. Letterhead that doesn't match the license. **A wage letter with no payroll.** For goods from China, CBP asks for wage payment records and output per worker, and recruitment records showing people came voluntarily. A letter saying workers are paid is not payroll. *Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, pp.47, 57, 58, 59.* ## Does the format of the file matter? ######  Yes, and it costs people days. Appendix C of the CBP guidance says how the packet should look: exhibits numbered and grouped by production stage, an index that says what each document proves, business-confidential information marked, scans that are searchable, and (for anything not in English) the original plus an English translation. A reviewer opens a folder. If they have to hunt for the smelter affidavit, or guess which of forty invoices is tier two, you lose the time you don't have. Chinese originals with English translations, indexed, is a bilingual job. *Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, Appendix C p.54.* WHERE WE COME IN ## What we do and what we don't ### We collect the China-side file. On site. Legal entity against the PI against the bank account. The address on the license against the factory you can walk. Who is actually in that factory. Input invoices, and whether they're real. Sub-supplier names and addresses, tier by tier, until the chain reaches the material. The payment trail. Dated photographs of your goods on the line. Input volume against output. Affidavits with the factory's chop that your counsel can file. Then the packet is assembled through Asia Agent Pte Ltd, in the Appendix C format, Chinese and English, and your counsel submits it. ### What we are not. We are not US trade counsel. Your broker and lawyer file. A person in China does not stop a detention; the duty stays with you as importer of record, and CBP decides on the evidence. We are not the independent forced-labor auditor CBP describes. That's SGS in China or TÜV SÜD in Singapore and Asia; we coordinate it when the sector calls for it, at a rate we pass through. ## Not detained yet? Then you have the one thing every importer on this page has lost: time with no clock and no storage bill. The documents are the same whether CBP asks tomorrow or never. CBP's guidance says it plainly: importers who have the file ready in advance get released faster. Built before the hold, it's a project. Built during, it's a scramble at port rates. ###### That is what [Monthly Support is for. →](https://www.china-agent.com/monthly-support-packages?hsLang=en) *Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, p.50.*   FAQs ## Frequently Asked Questions   ##### [How long do I have to respond to a UFLPA detention? Thirty days from the date on the notice for a potential-input detention. You may request up to two 30-day extensions, to a maximum of 90, but approval is at the Port or Center Director's discretion. A Finding gives 30 days with no extension. A WRO gives three months.](https://www.china-agent.com/uflpa-detention-documentation#collapse1-dnd_area-module-8) Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, summary table.     ##### [Who pays for storage while the shipment is detained? You do. CBP's UFLPA FAQs state the importer is responsible for storage costs of detained shipments.](https://www.china-agent.com/uflpa-detention-documentation#collapse2-dnd_area-module-8)       ##### [What is the difference between an applicability review and an exception? Applicability review: you show UFLPA doesn't apply (no Xinjiang input, no listed entity anywhere in the chain). Exception: you accept it may apply and prove the goods weren't made with forced labor, to a clear-and-convincing standard. Granted exceptions are reported to Congress and published. Most China importers are in the first fight.](https://www.china-agent.com/uflpa-detention-documentation#collapse3-dnd_area-module-8) Applicability review: you show UFLPA doesn't apply (no Xinjiang input, no listed entity anywhere in the chain). Exception: you accept it may apply and prove the goods weren't made with forced labor, to a clear-and-convincing standard. Granted exceptions are reported to Congress and published. Most China importers are in the first fight.     ##### [What happens if one supplier in my chain won't provide records? Under Appendix B of CBP's June 2026 guidance, if production information is missing for even a single supplier, the submission is insufficient and the shipment is denied. The guidance also says an importer should consider finding a new supplier if one won't cooperate.](https://www.china-agent.com/uflpa-detention-documentation#collapse4-dnd_area-module-8)   .   ##### [How far up the chain does CBP go? As far as the notice and the product require. Apparel and silica-heavy goods often die at Tier 2 or 3, not at the exporter.](https://www.china-agent.com/uflpa-detention-documentation#collapse5-dnd_area-module-8)     ##### [My factory has a BSCI / ISO / SMETA audit. Does that count? Not for this. CBP's guidance says financial, environmental and general audits are not sufficient. It looks for an unannounced audit by an independent third party against the ILO's eleven forced-labor indicators.](https://www.china-agent.com/uflpa-detention-documentation#collapse6-dnd_area-module-8)       ##### [The goods shipped from Vietnam, Cambodia or Malaysia. Does UFLPA still apply? It can. UFLPA follows the input, not the port of loading. If Chinese material or a listed entity sits behind the third-country invoice, the presumption applies. We verify whether real transformation happened in the third country, and what went into it.](https://www.china-agent.com/uflpa-detention-documentation#collapse7-dnd_area-module-8)       ##### [Will lab testing help? It can. CBP says it considers laboratory results (isotopic origin testing for cotton and some minerals) as part of the total evidence package, if the results are credible and specific to the detained goods. It supports the file; it doesn't replace it.](https://www.china-agent.com/uflpa-detention-documentation#collapse8-dnd_area-module-8) It can. CBP says it considers laboratory results (isotopic origin testing for cotton and some minerals) as part of the total evidence package, if the results are credible and specific to the detained goods. It supports the file; it doesn't replace it.   ##### [Can my customs broker handle this from the US? They file what you give them. They cannot walk the factory, match the chop to the license, or collect tier-two records in China.](https://www.china-agent.com/uflpa-detention-documentation#collapse9-dnd_area-module-8)       ##### [Can someone other than me submit the documents to CBP? Yes. CBP's FAQs say a third party may submit supply-chain documentation, but the importer should be notified. In practice: we collect, Asia Agent Pte Ltd assembles, your counsel or broker submits, and you know every step.](https://www.china-agent.com/uflpa-detention-documentation#collapse10-dnd_area-module-8)     ##### [Do you work for the factory? No. No sourcing. No commission from any factory. It's the reason a factory's own suppliers will talk to us.](https://www.china-agent.com/uflpa-detention-documentation#collapse11-dnd_area-module-8)     ##### [Is this legal advice? No. We are not US trade counsel. We collect the China-side records. Your counsel files.](https://www.china-agent.com/uflpa-detention-documentation#collapse12-dnd_area-module-8) ##### [I don't have a detention yet. Does this page apply to me? If your product or its inputs touch cotton, apparel, polysilicon, PVC, aluminum, steel, copper, lithium, seafood, caustic soda, tomatoes or red dates (the twelve sectors CBP prioritizes), the file is worth building before anything happens. Before the hold, you're not paying storage while you build it.](https://www.china-agent.com/uflpa-detention-documentation#collapse13-dnd_area-module-8) ### Need the importer side covered too? This page covers the China-side file: what your suppliers have to prove. Importer-side work, like a CBP audit response, getting audit-ready or building your own compliance program, is an Asia Agent project Eldad leads himself. [Book a meeting with Asia Agent](https://asia-agent.com/book-a-meeting) → ## Related ###### [UFLPA Detention:  What CBP Wants and Your 30 Days](https://www.china-agent.com/uflpa-detention-documentation?hsLang=en) [CF-28 /  CF-29: When CBP Questions an Entry](https://www.china-agent.com/cf-28-response-china?hsLang=en) [China Origin via Cambodia or Vietnam](https://www.china-agent.com/country-of-origin-china-vietnam?hsLang=en) [CBP Detained My Shipment from China](https://www.china-agent.com/cbp-detained-shipment-china?hsLang=en) [The Ten Things CBP Will Ask Your Supplier For](https://www.china-agent.com/blog/10-things-cbp-will-ask-you-to-produce?hsLang=en) [Monthly Support:  The File, Kept Every Month](https://www.china-agent.com/monthly-support-packages?hsLang=en) [Your Own Employee in China](https://www.china-agent.com/employee-in-china?hsLang=en)   China Situation Call ## Thirty minutes. Bring the notice. 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