Why Choose This Service
On-site factory verification in China and Vietnam
We inspect the actual production site and document how your goods are made.
Country-of-origin verification
We verify that the manufacturing process meets substantial transformation rules.
UFLPA and forced-labor diligence
Supplier screening and documentation to support CBP inquiries.
AD/CVD and tariff circumvention screening
We identify duty scope risk before CBP does.
Complete CBP evidence pack
Invoices, supplier declarations, production records, and audit-ready documentation.
Supplier contracts with audit rights
Legal leverage if suppliers fail to provide required documentation.
What CBP Actually Checks
When CBP audits an importer, they examine whether the information filed at entry matches the reality of the supply chain.
The most common audit issues include:
- incorrect country of origin
- incomplete supplier documentation
- AD/CVD scope exposure
- valuation inconsistencies
- missing internal compliance controls
Our role is to verify the supply chain and prepare the documentation before those questions arise.
Who Uses This Service
Importers usually use this service when:
• expanding sourcing in China or Vietnam
• shifting production out of China
• preparing for a CBP audit
• facing increased tariff scrutiny
• building a compliance program before scaling imports
What We Deliver: A Complete CBP Audit Evidence File
Every CBP Audit Readiness project is built around your suppliers, SKUs, and compliance risks.
We verify the factory, review the origin and duty exposure, and assemble the documentation CBP expects to see during an audit or investigation.
1. Factory Verification Report
On-site factory meeting and physical inspection
Geo-tagged photos and video proof of the production site
Bill of Materials (BOM) mapped to HS classifications
Production flow and chain-of-custody documentation
Factory license verification and production capacity review
Cross-check with trade data and declared export activity
2. AD/CVD Risk & Country-of-Origin Verification
Department of Commerce scope screening for relevant AD/CVD orders
Country capacity review to flag suspicious sourcing claims
On-site confirmation of declared manufacturing locations
Substantial transformation analysis (change in name, character, or use)
Country-of-Origin Determination Memo prepared for CBP scrutiny
Red-Flag Report with options:
- pay duties
- switch supplier
- restructure contracts
3. CBP Audit Readiness Packet
Verified invoices matched against bank wire payments
Supplier affidavits confirming origin and valuation declarations
Container seal logs and chain-of-custody documentation
UFLPA due diligence checklist and forced labor screening
Classification review including HTS evaluation and ruling checks
Valuation reconciliation covering assists, molds, royalties, and commissions
Pre-entry internal audit comparing invoice, packing list, BL, ISF, and entry summary
4. Customized Legal Contracts
Drafted with licensed lawyers in China and Vietnam
Jurisdiction and inspection rights built into supplier agreements
Penalty clauses for misrepresentation or false declarations
Indemnification clauses assigning liability to the supplier when statements prove false
Annual renewal mechanism to keep agreements enforceable
5. Supplier Negotiation & Compliance Enforcement
Direct negotiation with suppliers to obtain compliance documentation
Resolution of supplier refusals or resistance to providing records
Escalation strategies when factories attempt to avoid documentation
Fallback options:
- independent third-party audits
- supplier replacement
- termination of sourcing
6. Ongoing Monitoring
Annual supplier re-verification
Spot checks comparing affidavits against real production
Contract refresh and documentation updates
Continuous monitoring to detect changes in sourcing or production
Investment
A CBP Audit Readiness project typically ranges from $7,000 to $18,000, depending on:
Number of suppliers involved
Product complexity and SKU count
Depth of documentation and legal contract work required
Each engagement is scoped individually so clients only pay for the suppliers and compliance work relevant to their supply chain.
Why Importers Choose Asia Agent
No remote shortcuts — every factory verification is conducted on site in China or Vietnam
Enforceable supplier contracts drafted with local lawyers
Supplier leverage — we negotiate directly with factories to secure compliance
Full compliance coverage — classification, valuation, origin, AD/CVD, UFLPA, and forced labor risks
Evidence files prepared to withstand CF-28 requests, CF-29 notices, detentions, and regulatory challenges
Before CBP audits an importer, the agency expects documentation proving the origin, valuation, and supply chain behind each shipment.
Here’s the checklist every importer should satisfy to be CBP audit-ready:
- verified factory name, license, address, photos, and production capacity
- Bill of Materials (BOM) with input suppliers, HS codes, cost breakdowns
- Classification documentation & internal memo per SKU (with rulings, essential character analysis)
- Valuation worksheets for assists, royalties, commissions, and proof of payment
- Country-of-Origin and substantial transformation proof
- UFLPA traceability — raw material through finished good, transport and invoice records
- Signed supplier contracts with liability, audit/inspection rights, penalties, and indemnification
- Pre-entry internal audit: invoice vs packing list vs BL vs ISF vs entry summary
- Document retention and version control (minimum five years)
- Fallback plan for non-cooperative suppliers
Next Step
Next Step: Request a Consultation
We will review your suppliers, SKUs, and sourcing structure, identify compliance gaps, and design an audit readiness plan tailored to your supply chain.
