UFLPA Evidence Checklist: 26 Importer Checks

Before a U.S.-bound shipment is released for production, the importer should be able to trace every material and processing step to identified facilities, reconcile that map to commercial records, screen all entities, and produce the evidence as one coherent shipment file. A supplier declaration or a certificate stating “no forced labor” is not a substitute for traceability.

This 26-point checklist is designed for importers, sourcing teams, customs brokers and DDP logistics coordinators. It helps organize evidence before shipment and prepare for an applicability review or detention. It is not a legal opinion, does not guarantee admissibility, and does not replace current CBP guidance or advice from qualified customs counsel.

What the UFLPA changes for importers

The Uyghur Forced Labor Prevention Act creates a rebuttable presumption for goods mined, produced or manufactured wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List. CBP explains the basic rule in its UFLPA overview. The presumption can reach inputs several tiers upstream from the final factory, so screening only the exporter or assembly plant is not enough.

DDP terms do not remove the U.S. importer’s exposure. The contract may allocate freight, duty and delivery costs to the seller, but CBP still evaluates the entry, importer, merchandise and supporting evidence. Confirm the legal roles using DDPexpert’s importer-of-record guide before accepting a DDP structure.

The evidence must tell one consistent story

The 26-point UFLPA evidence checklist

A. Define the shipment and risk boundary

Freeze the exact imported product. Record SKU, model, material composition, production lot, purchase order, quantity and planned entry.
Break the product into traceable inputs. List raw materials, components, subassemblies, packaging and outsourced processing that could carry geographic or entity risk.
Assign the HTS classification and country-of-origin analysis. Keep the rationale with the file; an incorrect classification can distort risk screening and entry data.
Identify the importer of record and decision owner. Name the party authorized to instruct the broker, receive CBP notices and decide whether to contest, export or abandon detained goods.
Set a written release gate. Production, final payment and shipment should not proceed until required evidence is complete and reviewed.

B. Map the full supply chain

Name every facility, not only every company. Capture the physical address and function of mines, farms, processors, mills, smelters, component plants, assembly factories and warehouses.
Record legal names and aliases. Include local-language names, former names, parent companies, subsidiaries and commonly used trading names.
Show material flow between tiers. A diagram should explain which input moves from which facility to the next, with no unexplained jump.
Identify traders and consolidators. Intermediaries must be mapped even if they never physically process the goods.
Document subcontracting controls. Require prior approval for new processors, temporary capacity and overflow production.
Confirm facility addresses independently. Compare business registrations, invoices, transport records, websites and mapping evidence; investigate conflicting locations.

C. Screen entities and materials

Check the current UFLPA Entity List. Screen the full chain against the live DHS UFLPA Entity List, not a saved spreadsheet that may be outdated.
Screen name variants. Search Chinese characters, transliterations, abbreviations, former names and related entities.
Review ownership and control. Look beyond an exact-name match when a facility is owned, operated or supplied by another entity of concern.
Apply commodity-specific scrutiny. Focus additional work on inputs and sectors identified in the current FLETF strategy and CBP enforcement information.
Rescreen before shipment. Repeat screening when the bill of materials, supplier, facility or entity list changes.

The 2025 FLETF strategy update documents additions to the Entity List and enforcement priorities. Treat it as a current-risk input, not as a replacement for shipment-level tracing.

D. Reconcile commercial, transport and production records

Match purchase orders and supplier invoices. Names, dates, quantities, descriptions and lot references should connect each tier.
Reconcile input and output quantities. Explain conversion ratios, scrap, yield, work in process and inventory carried between production runs.
Match payment records to transactions. Identify the payer, payee, invoice and amount; investigate third-party payments or unexplained offsets.
Connect transport documents to material flow. Bills of lading, waybills, delivery notes, warehouse receipts and gate records should support the mapped route.
Verify production timing and capacity. Machine, labor, energy, inventory and batch records should make the claimed output plausible.
Align the customs documents. The commercial invoice, packing list and entry description should identify the same product, supplier, quantity and value. Use the DDP commercial invoice checklist to find inconsistencies before pickup.

E. Validate the shipment and preserve the file

Inspect lot and carton identifiers. Photograph production marks, pallet labels, container loading and seals so physical goods can be connected to the evidence set.
Use scientific testing as supporting evidence only. CBP’s isotopic-testing guidance states that testing may assist supply-chain validation but is generally not sufficient by itself to obtain release.
Build an indexed evidence file. Add a contents page, supplier-and-facility table, document cross-reference, English explanations and translations for key records.
Retain version and review records. Save who collected each document, when it was reviewed, what discrepancy was found and how it was resolved.

Supplier evidence request template

Send the request before issuing the production order. Require the supplier to identify every upstream source and to notify the buyer before substitution.

If CBP detains the shipment

Do not send an unstructured data dump. Read the detention notice, confirm the response deadline and determine whether the importer will request an applicability review, attempt to rebut the presumption, export the goods or pursue another available option with counsel. CBP’s forced-labor FAQ explains that importers may export detained shipments or submit information intended to demonstrate admissibility.

Preserve the complete entry and communication record.
Assign one response owner and one document index.
Map every submitted exhibit to a specific supply-chain fact.
Explain discrepancies rather than hiding them.
Use DDPexpert’s CBP information-request guide to structure a fact-based response workflow, while following the actual notice and legal advice for the case.

Frequently asked questions

Is a supplier affidavit enough for UFLPA compliance?

No. It can support the file, but it does not trace raw materials, transactions, transport and production. The importer needs evidence that is specific to the goods and reconciles across the full chain.

Does screening the UFLPA Entity List complete due diligence?

No. List screening is essential but does not prove where unlisted suppliers obtained their inputs. Map and verify upstream sources and monitor changes.

Can an isotopic test replace supplier records?

No. CBP describes testing as one evidentiary input. Use it to challenge or support the documentary story, not to replace the transaction and production trail.

Shipment release decision

Release the shipment only when the product and lot are frozen, the entire supply chain is identified, entities and aliases are screened, upstream records reconcile, production capacity is plausible, physical shipment marks connect to the evidence, and the importer has an indexed file ready for review. If a critical tier remains undisclosed or the records conflict, pause shipment and resolve the gap before the goods enter the U.S. supply chain.

UFLPA Supply Chain Evidence Checklist: 26 Checks Before U.S. Import