Reasonable Care File
Supplier tracing, built to CBP guidance

Our team builds your Reasonable Care File in your supplier's factory, with your supplier, before CBP asks.

If you import from China, you've probably heard a lot lately. New CBP guidance. Detentions. CF-28s. Forced labor rules. It can sound like the door is closing.

It isn't. What's changing is simple: CBP now wants to see that you know who made your goods, from what, and who got paid. Not "my supplier told me." Proof from the factory.

For a good supplier, most of that proof already exists. It sits in the factory, mostly in Chinese. The work is collecting it, matching it and keeping it current. That's what a Reasonable Care File is: one file per supplier, built with them, and it belongs to you.

I've worked with Chinese factories since 2009. This is the most useful change I've seen in that time.

What's changing, and why

The US has banned goods made with forced labor for almost a hundred years. What's new is how seriously it's checked.

The Uyghur Forced Labor Prevention Act has been in force since June 2022. In June 2026, CBP published new guidance for importers: trace your goods back to the raw material, through every tier of supplier. The EU is moving the same way, with its own forced labor ban from December 2027.

The reasons are good ones. Keep forced labor out of the products people buy. Stop goods being routed through a third country to hide where they were made. Make sure honest factories aren't undercut by ones that cut corners. The end result is better, safer products, made by factories that can show how they work.

What it means inside the factories

For years, buying from China ran on trust and a contact. A factory, sometimes a trading company in front of it, a price, a shipment. Nobody on your side asked who made the fabric or where the aluminum came from.

That way of working has hit its limit. Not because suppliers changed, but because the questions did.

Here's what we see in the factories: most suppliers are good. They want to keep your business. They just haven't been asked for this before, and nobody has explained what CBP wants or why. Once someone sits down with them and walks through it, most say yes.

A few can't. Their materials come from places they can't show, or the "factory" turns out to be someone else. That's not something anyone can fix, and it's far better to find out before you place the order than at the port.

It doesn't have to cost a fortune

This isn't a factory rebuild or a new supplier search. For most suppliers it's paperwork they already have: licenses, bills of materials, purchase records, export papers. Collected, matched against your orders, and kept up to date.

The real cost is time and trust. You need someone in the room the supplier is willing to open up to.

Your broker can't do this part for you

The law puts reasonable care on you, the importer (19 U.S.C. § 1484). In July 2026, the DOJ/DHS Resource Guide to Trade Fraud Enforcement said it again: relying on your broker or your supplier is no defense.

Your broker files your entry, and a good one is worth what you pay. But brokers and compliance consultants work from a desk in the US. They can run a program. They can't walk into your supplier's office and come out with the bill of materials.

Those documents sit with people who only hand them to someone they trust. Our team is already in the room, paid by you and nobody else.

Nobody in China works only for you. We do.

Why start now

The stakes went up this year. Executive Order 14411, signed in June 2026, ordered a penalty floor of at least 50% and an end to mitigation for repeat offenders. Since September 18, 2026, CBP has been voiding importer numbers that carry inaccurate data (the Form 5106 notice). And on September 2, 2026, CBP asked whether importers should have to submit the export papers their supplier filed with Chinese customs. That one is only proposed, with comments due December 1, 2026.

None of this is a reason to panic. It's a reason not to wait. Suppliers need time to get used to new questions, and trust takes longer than paperwork.

What you can do yourself this week

You don't need us for the first steps. Start with your main supplier:

• Ask for the business license. The Chinese legal name on it should be the company on your invoice.
• Ask for the bill of materials for your product.
• Ask who supplies the main materials. Get company names, not "a factory near us."
• Put every invoice next to your contract and match the bank account. Same company, every time. If a new name shows up, ask why before you pay.

Ask politely, and explain why. A good supplier will give you most of this. What they hold back tells you where to look next.

What's inside a Reasonable Care File

One file per supplier, in five sections:

1. Who the supplier is. Business license, ownership, address, bank details, export rights.
2. What they can make. The production line, the machines, the workforce, with dated photos.
3. Where every material comes from. The bill of materials, the tier-2 suppliers, the origin.
4. Each shipment traced. PO, invoices, export declaration, payment and bill of lading, all matched.
5. Every change logged. What changed, when, and what we did about it.

We record what we saw, on the date we saw it. If something is missing, the file says so, so your broker and counsel aren't surprised later.

How our team gets the documents

Over tea, not threats. Demands make suppliers close up. A conversation makes them open up.

So our team sits with them face to face, explains what CBP is asking and why, and helps them get it right. That's how suppliers end up handing us what they'd never email to a stranger, like the bill of materials and the names of their own material suppliers. And they come out of it better prepared for every other buyer too.

You get a PDF summary each week and each month. Our management team signs off before anything goes to you.

The file is yours to keep. You own it outright, built by the only party in your chain that's paid by you.

Where to start

The Reasonable Care File comes with two of our services. Pick the one that fits how you work.

Monthly Support

Our team builds a Reasonable Care File for each supplier on your plan and keeps it current. Same tiers, same prices. See Monthly Support

Employee in China

Your own full-time person in China handles all your supply chain needs, and building your Reasonable Care File with our team is one of them. See Employee in China

One supplier first

Start with the Factory Reality Check plus the CBP Evidence Score: $795 plus $400, so $1,195 together. It's our in-person due diligence visit, upgraded and built with the Reasonable Care File in mind. Already paid for a $95 Supplier Reality Check? That $95 counts toward it within 30 days. See Due Diligence

What the Reasonable Care File is not

It's not legal advice, not a customs filing and not a certificate. Your broker and your counsel use what we build, and CBP decides.

China Agent Ltd. Not legal advice. We are not US trade counsel. For your entries, a CF-28 or a detention, talk to your licensed customs broker or trade counsel.

Questions about the Reasonable Care File

What is a Reasonable Care File?

A Reasonable Care File is one file per supplier that shows who the supplier is, what it can make, where every material comes from, how each shipment matches its paperwork, and every change over time. China Agent builds it inside the supplier's factory, with the supplier, and keeps it current. The importer owns it. It is built to CBP's June 2026 forced-labor guidance for importers.

Do the new CBP rules mean I should stop buying from China?

No. They mean you need to show where your goods come from. Most Chinese suppliers can provide the documents CBP expects once they understand what's needed. The suppliers who can't are better identified early, before an order, than at the port.

Will a Reasonable Care File raise my costs?

For most suppliers the documents already exist, so the work is collecting, matching and updating them, not changing how the factory operates. The Reasonable Care File comes inside Monthly Support and Employee in China at the same tiers and prices.

Is a Reasonable Care File a compliance service?

Only on the China side. China Agent builds the supplier evidence that shows your reasonable care. The duty of reasonable care stays with the importer under 19 U.S.C. § 1484, the customs broker files the entry, and CBP decides. The Reasonable Care File is not legal advice, a customs filing or a certificate.

Who owns the Reasonable Care File?

The importer does, outright. China Agent builds and updates the file, is paid only by the importer and takes no commission from any factory. US law expects importers to keep entry records for five years (19 U.S.C. § 1508), so the file stays with you.

Can my customs broker or trade lawyer use the Reasonable Care File?

Yes. The Reasonable Care File is built for your broker and counsel to use. China Agent builds the factory side; your broker files and your counsel advises. China Agent does not file entries, classify goods or give legal advice.

Does the Reasonable Care File work for suppliers in Vietnam, India or Indonesia?

Yes. For a single supplier in one country it's the same Reasonable Care File. When your goods move across countries before shipping, say fabric from China sewn in Vietnam, every step has to trace back and connect. That becomes a program under Asia Agent, part of the same network.

What about the EU?

The EU Forced Labour Regulation applies from December 14, 2027. The Reasonable Care File China Agent builds today follows US guidance, and the EU fields are added in 2027. EU importers will get the same file plus the EU fields.

How much does a Reasonable Care File cost?

It comes inside two services. Monthly Support clients get a Reasonable Care File for each supplier on their plan, at the same tiers and prices. Employee in China clients have their person build the file with China Agent's team, at the same tiers and prices. To start with one supplier, the Factory Reality Check with the CBP Evidence Score is $1,195 ($795 plus a $400 add-on), and a $95 Supplier Reality Check credits toward it within 30 days.

What does CBP's June 2026 guidance ask importers to show?

CBP's Forced Labor Enforcement Operational Guidance for Importers, June 2026, asks importers to trace their goods back to the raw material, through every tier of supplier. If an importer can't give production information for even one supplier in the chain, the guidance says the whole submission is insufficient. China Agent builds the Reasonable Care File to follow that trace.