Factory audit vs. supplier screening — what each one proves

The template above shows the shape: who was audited and how, an overall score and rating with a validity date, scores by section, the findings, and the fixes and follow-up. Read the first block closely. The auditee is the factory, and it can be a different legal company from the vendor you got the quote from and will pay. Record both names exactly as written.

A manufacturing audit scores capacity, machinery and the quality system: can the order be made, and made consistently? A social audit records hours, wages, insurance, safety and hiring on the day. A security audit checks areas like staff, physical access, container seals, procedures and cybersecurity, the areas CBP's voluntary CTPAT program covers for companies that join. A strong score on one says nothing about the others.

Names against government lists: the UFLPA Entity List kept by the Forced Labor Enforcement Task Force, CBP's Withhold Release Orders and Findings, and the sanctions and export-control lists, like OFAC's. It matches the name to a legal company, checks aliases and known parents, and reports what was searched and found, with the source and date. It can be rerun in minutes when a list changes.

A screening can't see working conditions. An audit can't see a government list. That's the whole difference.

No. CBP's guidance lists what it may ask for when an importer seeks an exception to the UFLPA presumption: the importer's due-diligence system, including a map of the supply chain back to raw materials; how the supply chain is managed; and evidence that the goods weren't made with forced labor. Credible audits that look for forced-labor signs, and fixing what they find, are one item on that list. CBP says those audits should be unannounced and done by independent auditors.

So an audit is one input into due diligence. It isn't, on its own, the clear and convincing evidence about the goods that an exception needs, and an audit score can't show whether a company or its parent is on the Entity List. Anyone selling an audit as a forced-labor clearance is claiming more than the document can carry.

Check whether it was announced; an announced audit is prepared for, and the score describes that day. Check the validity date, because scores expire. Check the auditee's legal name against the vendor's and against your invoices. And read the findings before the score: three findings about overtime and insurance tell you more than a social score of 4.8 out of 5.

Then look at what came next. Findings with no fix plan, no dates and no follow-up audit are a snapshot. The plan and the re-audit are what a broker or attorney would later ask to see.

The screening. It's cheap, fast and repeatable, and it belongs before the deposit: a supplier on a list is a supplier not to pay. An audit comes when the volume justifies a visit, or when a buyer's own program requires one. Both go in the same file, with the test and inspection reports, because that file is what due diligence looks like when someone asks to see it.