UFLPA Compliance Services | Prove No Forced Labor in Supply Chains

The UFLPA bans the import of goods made in whole or in part with forced labor from Xinjiang, China. CBP applies a “rebuttable presumption” that all goods from Xinjiang are linked to forced labor unless the importer can provide clear, verifiable evidence otherwise. U.S. importers must show reasonable care and due diligence to avoid detentions, seizures, and penalties.

Even if your supplier is located in Guangdong, Zhejiang, or other provinces, CBP may still trace raw material origins back to Xinjiang. Cotton, polysilicon, tomatoes, and other high-risk materials are closely monitored. Importers must map the entire supply chain, not just the final factory, to prove goods are free of forced labor inputs.

Importers must provide:

• Supplier affidavits and certifications of no forced labor.

• Full Bill of Materials with raw material origin traced.

• Chain-of-custody documentation with factory names, addresses, and geo-tagged photos.

• Independent third-party verification and audit reports from China.

Our team conducts on-the-ground supplier verification across China, including site inspections, production flow documentation, and license checks. We gather affidavits, map raw material sources, and prepare an audit-ready compliance file tailored for CBP scrutiny.

High-risk categories include textiles (cotton, yarn, fabric), solar (polysilicon), tomatoes and food products, electronics, footwear, and industrial inputs with raw materials from Xinjiang. Even unrelated sectors can face exposure if sub-suppliers source upstream materials from the region.

Asia Agent can begin on-site verification in China within days. A standard UFLPA compliance file, including affidavits, production records, and origin mapping, can be prepared within 2–3 weeks depending on supplier cooperation.

CBP may detain or seize goods at port, issue penalties, or pursue enforcement actions. Beyond financial losses, importers risk reputational damage, supply chain disruptions, and losing access to U.S. markets.

UFLPA requires deeper raw material origin verification. While general CBP audits focus on valuation, classification, and invoices, UFLPA cases demand affidavits, supplier interviews, and on-the-ground evidence proving no forced labor was used at any stage of production.

We are boots-on-the-ground in China, providing:

• Direct factory visits & geo-tagged inspections.

• Forced labor due diligence and affidavits.

• Supply chain mapping down to raw material sources.

• Contracts enforceable under Chinese law.
  This ensures your compliance file meets CBP’s strict rebuttable presumption standard.