Blog

Before Your Next Order in China: 10 Supplier Disclosures for CBP Compliance

Written by Eldad Shashua | Oct 3, 2025 1:00:00 AM

Before You Place the Next Order in China: 10 Supplier Disclosures You Need for CBP Compliance

Most importers assume that once a price is agreed and a sample is approved, the deal is locked. The factory will produce what was promised, at the agreed quality.

But this is where most buyers misread the game. In reality, once the order is secured, the factory’s priority shifts: how to add back profit by cutting costs.

  • Material grades get downgraded as the factory hunts for cheaper suppliers, often ignoring compliance risks.

  • Production can be quietly shifted to a prison workshop where labor is cheapest—and quality is impossible to monitor.

  • Extra workers may be pulled in off the street, underage or undocumented, without benefits or protections.

  • Upstream suppliers—the suppliers of your supplier—may be swapped without disclosure, leaving you blind to compliance and safety conditions.

To the factory, these are just options. To you, they’re violations waiting to be uncovered in a CBP audit.

The 10 Disclosures You Must Demand Before Placing an Order

If you want to stay ahead of CBP, don’t rely on promises. Demand documentation—upfront.

  1. Bill of Materials (BOM) with HS Mapping
    Require a full BOM tied to tariff codes, not just a simplified list.
  2. Factory License & Legal Entity Proof
    Confirm the legal manufacturer is the same entity on the export license and bank account.
  3. Origin Proof for Raw Materials
    Ensure traceability back to mills, farms, or smelters—not just the final assembler.
  4. Subcontractor Disclosure
    Check whether the factory’s capacity matches your order. If not, find out where the excess will be made.
  5. Worker Rosters
    Verify legal age, wages, hours, and benefits—don’t accept vague statements.
  6. Labor Sourcing Methods
    Demand proof no prison or forced labor is involved in production.
  7. Supplier Affidavits
    Signed statements covering COO, valuation, and classification.
  8. Invoice-to-Wire Reconciliation
    Confirm the money you send matches the invoices and what’s declared to Customs.
  9. Production Flow Records
    Secure documents showing where and how each step of production happens.
  10. Audit & Contractual Rights
    Your contract must guarantee inspection rights and penalties for hidden changes.

Why Contracts Close the Gap

Even if your supplier swears they won’t cut corners, the economic incentive is always there. That’s why contracts must be detailed and enforceable under Chinese law.

Your contract should stipulate:

  • No production relocation without written consent.

  • No substitution of suppliers without prior approval.

  • No subcontracting to secondary workshops or prisons.

  • Audit and inspection rights at any time.

  • Automatic financial penalties for undisclosed changes.

  • Renewal of compliance affidavits before, during, and after production.

This isn’t about mistrust—it’s about control. Without these provisions, you’re exposed the moment your supplier decides to “optimize.”

Why This Matters for CBP

CBP expects you to show reasonable care. That means proving you didn’t just trust a supplier’s word—you demanded documentation, verified disclosures, and locked in obligations through enforceable contracts.

When CBP requests evidence, you must be able to show:

  • BOMs, not just invoices

  • Bank wire reconciliation

  • Worker and production records

  • Contracts that prohibit the very shortcuts factories are most likely to take

Without this, your compliance file collapses under scrutiny.

Every order in China carries an unspoken risk: the factory’s profit depends on giving you less than you think you’re buying.

Asia Agent changes that dynamic. We secure the disclosures your suppliers don’t want to give, draft contracts that remove the gray areas, and build audit-ready files that stand up in front of CBP.

Book a Strategy Call today — protect your next order before production even begins.

FAQ 

Q: What supplier disclosures should U.S. importers demand from Chinese factories?
Importers should require a real BOM tied to HS codes, factory licenses that match the exporter and bank account, origin proof for raw materials, and full subcontractor lists. Without this, CBP may detain shipments.

Q: Why does CBP care about subcontractors in China?
If your main supplier outsources production to unapproved workshops—or even prison labor facilities—CBP will hold the U.S. importer liable. That’s why subcontractor disclosure is critical.

Q: Can CBP detain shipments even if the sample was approved?
Yes. A clean sample does not guarantee compliant production. Factories often change materials or suppliers after orders are placed. CBP looks at production records and raw material origins, not just samples.

Q: How can importers confirm their Chinese supplier isn’t using forced labor?
Independent, on-the-ground verification is required. Importers must also have contracts granting inspection rights and signed affidavits from suppliers, backed by penalties for false statements.

Q: What should a CBP compliance contract with a Chinese factory include?
A strong contract must ban production relocation, supplier swaps, and subcontracting without approval. It must include audit rights, affidavit renewals, and automatic penalties for hidden changes.

Q: How does Asia Agent help importers sourcing from China prepare for CBP audits?
Asia Agent builds audit-ready files: supplier evidence packs, legal contracts drafted with Chinese lawyers, and factory audits with geo-tagged proof. This ensures U.S. importers have the evidence CBP requires.