CBP detained your shipment under UFLPA. You have 30 days, and the proof is in a factory in China.
This is serious, and it is manageable. Under UFLPA, CBP presumes 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. Most Chinese suppliers can show where their materials come from once they understand what's needed.
The way through is records, not promises. A letter from your supplier saying "no forced labor" isn't enough on its own, but for a good supplier most of the records behind it already exist in the factory, mostly in Chinese.
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. Reasonable care stays with you, the importer, and a US court has ruled that relying on your broker or your factory doesn't replace it. We get the China-side file. Your broker and counsel submit it.
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 importer can rebut it with records. That is the whole law in one sentence.
The reasons behind it 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 result is better, safer products.
Look at the notice. It will be one of three things, and they are not the same:
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 a seizure, not a detention, so export isn't an option. You have 30 days to petition.
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?
| 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 |
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. You can do all of it yourself.
1. Read the notice properly.
2. Contact the CBP officer named on the notice.
3. Tell your customs broker and, if you have one, your trade counsel.
4. Get your supplier's legal Chinese name and the factory address.
5. Keep CBP contact with you and your broker.
6. Decide early which route you're on.
Which route am I on: applicability review or exception?
Two routes, and each needs a different file.
Applicability review.
Exception.
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.
One line in the guidance matters most. Appendix B says that if production information is missing for even one supplier in the chain, the submission is insufficient. So the goal is a complete chain, built one supplier at a time.
We've seen a five-tier file held up by a sixth name: a small parts supplier nobody thought mattered. It's worth checking every name early.
Why it takes work: those records sit with companies that have never met you, in Chinese. Most of them are good suppliers. They just haven't been asked for this before, and nobody has explained what CBP wants or why. An email from abroad asking a tier-two supplier to name its smelter rarely gets far. A face-to-face conversation usually does. A few can't show their chain, and it's far better to learn that before the next order than at the port.
Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, Appendix E pp.56–57; Appendix B pp.49–50.
What doesn't work?
These six things are often offered first. They're well meant, but on their own they don't carry the file:
The supplier's "no forced labor" letter. Self-issued, so on its own it carries little 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 may be rightly proud of its binder. It's useful, but it isn't the document CBP asks for here.
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. A tidy file saves 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. When the smelter affidavit is easy to find and every invoice is labelled by tier, the review goes faster. Chinese originals with English translations, indexed, is a bilingual job.
Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, Appendix C p.54.
What we do and what we don't
We collect the China-side file. On site.
The address on the license against the factory where the goods are made. 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.
We get there by sitting with your supplier and its own suppliers face to face, explaining what CBP is asking and why, and helping them get it right. 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.
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 a separate third-party audit firm; we coordinate it when the sector calls for it, at a rate we pass through.
Not detained yet?
Then you have time, and that makes this much easier.
The documents are the same whether CBP asks tomorrow or never. For a good supplier most of them already exist, so the work is collecting them, matching them and keeping them current. Built before a hold, it's steady work with your supplier. Built during one, it runs against CBP's date. Our team builds those documents into a Reasonable Care File for each supplier and keeps it current.
That is what Monthly Support is for. →
Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, p.50.
Frequently Asked Questions
Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, summary table.
Need the importer side covered too?
This page covers the China-side file: what your suppliers have to prove. Importer-side work, like answering CBP directly or setting up your own reasonable care program, is an Asia Agent project Eldad leads himself.
Book a meeting with Asia Agent →
Related
UFLPA Detention: What CBP Wants and Your 30 Days
CF-28 / CF-29: When CBP Questions an Entry
China Origin via Cambodia or Vietnam
CBP Detained My Shipment from China
The Ten Things CBP Will Ask Your Supplier For
Monthly Support: The File, Kept Every Month
Your Own Employee in China
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