Does moving production out of China avoid UFLPA?

It's a common move: a supplier in China draws UFLPA scrutiny, so production shifts to India or Bangladesh, and the new invoice shows a country other than China. That changes where the garment was made. It doesn't change where the cotton in it was grown, and under the UFLPA that's what the presumption turns on.

Yes. Under the UFLPA, goods mined, produced or made, wholly or in part, in Xinjiang, or by a company on the UFLPA Entity List, are presumed made with forced labor and barred from entry.

Say a shirt is cut and sewn in Bangladesh from cotton grown and ginned in Xinjiang. It was made in part with a Xinjiang input, so the finished shirt can fall under the presumption even though its last stop was outside China. Cotton is the classic case because the fiber passes through several countries on the way, and the concern travels with it.

Suppliers often offer a GOTS Transaction Certificate as reassurance. GOTS, the Global Organic Textile Standard, certifies organic content and its chain of custody: that certified-organic fiber stayed separate and tracked through spinning, weaving and making. The standard also has social and due-diligence criteria.

GOTS starts where farming ends, at the first processing step, so it checks that the fiber is organic, not where it was grown. A real GOTS certificate can still leave the UFLPA question open.

CBP doesn't publish one fixed checklist; it looks at everything the importer provides. Its guidance describes records that show where the raw materials came from, and a list of suppliers with each one's role, backed by the transactions and payments.

For a cotton garment, that means records reaching past the mill toward where the fiber was grown and ginned: the farm or gin, then the spinner, then the mill, then the factory. Paperwork offered "from the mill onwards" leaves out the half that matters, because the concern starts in the field.

Before the deposit. A supplier that won't document the fiber's origin before you pay is unlikely to produce it after a detention, when the bar is clear and convincing evidence and the work usually needs a customs attorney. Checking the supplier and its known parent against the UFLPA Entity List and CBP's forced-labor orders, with a dated record, is the low-cost first step.