UFLPA detention. The documents CBP wants are in the factory.
UFLPA flips the burden. CBP can presume forced labor if the goods, or inputs, connect to Xinjiang or to a listed entity. You rebut with clear evidence — or you lose the shipment.
A factory PDF that says “no forced labor” is not that evidence. CBP wants a trail: who made it, from what, where the inputs came from, who got paid, how it moved. That trail lives on the floor in China, often past Tier 1.
We are not US trade counsel. We collect the China-side file. 30 minutes to name the next move.
Who this page is for
UFLPA detention or applicability review
Entity List scare on a supplier or a sub-supplier
Counsel or broker said “we need tracing from China”
Cotton, apparel, polysilicon, PVC, aluminum, seafood, tomatoes, and the rest of the high-priority list
Cargo at LA/Long Beach, NY/Newark, Chicago, Houston, Miami, Seattle/Tacoma
What CBP is actually asking for
Ordinary business records that connect:
The imported SKU to a real manufacturer
That manufacturer to inputs
Those inputs to a place and a party
Money that matches invoices
Movement that matches bills of lading
If the story stops at the trading company, the package fails.
What fails
English certificate with no floor. Entity-list screen on Tier 1 only. “We buy from Vietnam.” Wage letter with no payroll. Audit from a firm that never entered the building.
What we pull on site
Legal entity vs PI vs bank. Address vs real production. Who is on the floor. Input invoices and whether they are real. Sub-supplier names and addresses. Payment trail. Dated photos. Chopped affidavits your counsel can file. Packet built through Asia Agent after you say yes.
What happens on the call
Frequently Asked Questions
No. We are not US trade counsel. We produce the China-side evidence your counsel and broker file. CBP and DOJ decide.
Applicability review: you try to show UFLPA does not apply (no XUAR, no listed entity). Exception: you accept it may apply and try to rebut forced labor with clear evidence. Both need factory-side documents. Bring the notice. We name which fight you are in.
No. That is the document that dies first.
Screening Tier 1 is not tracing. CBP asks about inputs. That is why someone has to be in the building.
Say terminal and entry number on the call. No LA office. The file is in China.
Same. Port holds the box. Proof is on the floor.
Same law. Say the port. We do not invent a local address.
Then we verify transformation and inputs on site. A third-country invoice is not a clean supply chain.
As far as the notice and the product require. Apparel and silica-heavy goods often die at Tier 2/3, not at the exporter.
No. No sourcing. No factory commission.
Live UFLPA hold goes first. Paper can start after the call. A visit is days if they open the door.
Yes. Building the file before the hold is the cheaper version of this job.
UFLPA hold on a China shipment?
Bring the notice. 30 minutes. We name what the factory-side file must contain.
Book
+86 15322086875
On the ground
Hong Kong, Guangzhou, Foshan, Shenzhen, Yiwu and Jinan.