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Forced-labor detention
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What goes in a UFLPA detention response package?

In one line

Records that trace your goods back to the raw material: the suppliers at each step, the payments, and the production and shipping records, organized so a CBP reviewer can follow them. The package argues one of two routes, and a customs attorney usually leads the work.

Read the CBP notice — free →
What goes in a UFLPA response package?
PartWhat it shows
Executive summaryWhy the goods should be released, up front
Annotated document listWhat each document is and how it connects to the others
Supplier list, flow chart and mapsEvery supplier at each step, with names and addresses, and how the goods were made
Purchase orders, invoices, proof of paymentThe money trail for each step
Production recordsWhat went in and what came out
Shipping recordsHow the goods moved through the chain
English translationsFor every foreign-language document

Source: CBP, Operational Guidance for Importers (June 2026), Appendix E; UFLPA Attachment 2-B; CBP, Guidance on Executive Summaries and Sample Tables of Contents

When is a UFLPA detention response package needed?

When goods are detained under the UFLPA. Goods tied to China's Xinjiang region or to a company on the UFLPA Entity List are presumed barred under the forced-labor ban. The importer can rebut that, and CBP decides on the documents sent during the detention. The package is those documents, gathered and organized.

For a forced-labor detention, the work is usually led by a customs attorney, who makes the legal calls. The package is what that work is built on.

Which route does the package argue?

One of two. An applicability review shows the goods and their inputs don't trace to Xinjiang or a listed company. An exception admits a tie and shows, by clear and convincing evidence, that these goods weren't made with forced labor. Which route fits is a legal and business call, made with a customs attorney.

What evidence does CBP look for in a UFLPA response?

The list in the table above: the suppliers at each step, a flow chart of how the goods were made, the purchase orders, invoices and proof of payment, production records and shipping records. Every foreign-language document needs an English translation; CBP says untranslated documents aren't enough.

The tracing has to reach the raw material, not stop at the last factory. Say you import cotton shirts. The records have to follow the cotton itself, and cotton is one of the high-priority sectors the law names, with tomatoes and polysilicon.

How is a UFLPA detention response package assembled?

CBP's guidance asks for an executive summary that says up front why the goods should be released, and an annotated list of the documents: what each one is and how it connects to the others. CBP also publishes sample tables of contents to follow. A reviewer working through hundreds of pages is helped or slowed by that order.

The importer gathers the set, and a customs attorney leads the response. Getting the tracing gathered, the documents listed and the translations flagged can start before the first meeting.

Next step

The free customs-hold check reads a UFLPA notice, assembles the cited evidence checklist CBP looks for, and drafts a response-starter package — the organized head start an importer or a customs attorney can build the response on.

Read the CBP notice — free →
When this changes

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Related

  • CBP detained my shipment under the UFLPA — what it means
  • How do I respond to a customs detention notice from CBP?
  • UFLPA Entity List: 190 entities after the October 29, 2026 update
  • Does moving production out of China avoid UFLPA?
  • What is a Withhold Release Order (WRO)?

Sources

  • CBP — Forced Labor Enforcement: Operational Guidance for Importers (June 2026: applicability review and exception; tracing from the raw material to the finished goods; Appendix E documents; untranslated documents not sufficient; executive summary) · read 2026-10-20
  • CBP — UFLPA Attachment to the Notice of Detention (sample Attachment 2-B: suppliers with names and addresses, a flow chart, maps; purchase orders, invoices, proof of payment; transportation documents; English translations) · read 2026-10-20
  • CBP — Guidance on Executive Summaries and Sample Tables of Contents (forced labor; an executive summary, an annotated document list, sample tables of contents) · read 2026-10-20
  • govinfo — Public Law 117-78, Uyghur Forced Labor Prevention Act, § 2(d)(2)(B)(viii): high-priority sectors including cotton, tomatoes and polysilicon · read 2026-10-20
  • CBP — FAQs: UFLPA Enforcement · read 2026-10-20

Information current as of 2026-10-31.

Legal Disclaimer+

This report is an automated, informational screening tool only. Tiana & Co. is not a licensed customs broker and does not conduct customs business. This report does not constitute legal advice, a compliance determination, or a certification of admissibility for any supplier, product, or shipment.

Verdicts in this report are produced by deterministic code, not by a language model. The explanatory paragraph accompanying each check is model-generated and checked against the cited sources before delivery. No part of this report is reviewed by a person before it is issued, so every material finding and citation should be confirmed against the underlying government source before it is relied on.

This report reflects data available as of the report date. The OFAC SDN and Consolidated lists, the other U.S. Consolidated Screening List constituents, the UFLPA Entity List, CBP withhold release orders, CPSC's eFiling list, and regulatory guidance are updated frequently and without prior notice. Users should re-screen periodically and consult qualified counsel for compliance decisions.

Name-similarity results do not establish or rule out the identity of any company. Where multiple similarly named records exist, none should be treated as confirmed without independent verification against the primary government source.

This tool is not affiliated with, endorsed by, or a substitute for U.S. Customs and Border Protection, the U.S. Department of the Treasury, the Consumer Product Safety Commission, or any other government agency. No warranty is made as to the accuracy, completeness, or currency of any finding.

Use of this report for import, procurement, sanctions-compliance, or investment decisions is at the user's own risk. Anyone with compliance obligations under UFLPA, OFAC, or CPSC regulations should consult qualified legal counsel before making a transactional decision.

Legal Disclaimer

This report is an automated, informational screening tool only. Tiana & Co. is not a licensed customs broker and does not conduct customs business. This report does not constitute legal advice, a compliance determination, or a certification of admissibility for any supplier, product, or shipment.

Verdicts in this report are produced by deterministic code, not by a language model. The explanatory paragraph accompanying each check is model-generated and checked against the cited sources before delivery. No part of this report is reviewed by a person before it is issued, so every material finding and citation should be confirmed against the underlying government source before it is relied on.

This report reflects data available as of the report date. The OFAC SDN and Consolidated lists, the other U.S. Consolidated Screening List constituents, the UFLPA Entity List, CBP withhold release orders, CPSC's eFiling list, and regulatory guidance are updated frequently and without prior notice. Users should re-screen periodically and consult qualified counsel for compliance decisions.

Name-similarity results do not establish or rule out the identity of any company. Where multiple similarly named records exist, none should be treated as confirmed without independent verification against the primary government source.

This tool is not affiliated with, endorsed by, or a substitute for U.S. Customs and Border Protection, the U.S. Department of the Treasury, the Consumer Product Safety Commission, or any other government agency. No warranty is made as to the accuracy, completeness, or currency of any finding.

Use of this report for import, procurement, sanctions-compliance, or investment decisions is at the user's own risk. Anyone with compliance obligations under UFLPA, OFAC, or CPSC regulations should consult qualified legal counsel before making a transactional decision.

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© 2026 Tiana & Co. LLC · Import Intelligence for small importers · Not a licensed customs broker. Not legal advice. Sources and retrieval dates are shown with each result.