U.S. Import Compliance

Trace the material behind the Mexican finished lot

Mexican processing can add production steps without filling an upstream traceability gap. For a US importer, the question is whether the supply chain implicates the UFLPA and whether the records connect the goods to their actual material sources.

Under section 3(a) of the UFLPA, goods mined, produced or manufactured wholly or in part in Xinjiang, or produced by the entities specified in that section, are presumed prohibited and not entitled to US entry, subject to the statutory exception. This can involve goods made wholly or in part from implicated inputs, including through a third country. Chinese sourcing alone does not determine the outcome for every shipment. CBP UFLPA resources

Decide which evidence question is open

QuestionInformation to gatherReview to request
Is an entity potentially within the relevant list?Legal name, aliases, address, registration details, role and list versionIdentity resolution against the current official list
Does the shipped material connect to an implicated source?Actual producers, intermediaries, transport and batch links through productionSupply-chain tracing and an applicability review
Has CBP issued a notice?Full notice, entry and lot references, requested documents and response instructionsNotice-specific work with the importer and qualified counsel or specialist
Is an exception to the presumption being sought?The applicable statutory and CBP requirements and the evidence they requireA distinct exception analysis; evidentiary standards and disclosure requirements matter

An applicability review addresses whether the goods fall within the presumption. An exception under section 3(b) requires compliance with the prescribed guidance, full responses to CBP inquiries and clear and convincing evidence that the goods were not produced with forced labor. Follow the actual notice and current CBP instructions before choosing a response. UFLPA sections 3(a)–(b) · CBP’s distinction between the two reviews, January 26, 2024

Other forced-labor prohibitions may also require review. CBP forced labor questions

Follow one batch through the plant

For a metal part, start with the finished-lot packing list and the production order. Follow material consumption to receipt lots, invoices and transport documents, then identify the producing mill and upstream materials as relevant to the risk. Where inputs are mixed or split, keep the quantity relationship and the records that explain it.

A Mexican plant may know its distributor but be unable to identify the mill behind one of two coils. Record that missing link. A generic supplier statement cannot replace the absent batch evidence.

Link in the chainUseful record and cross-check
Finished goods to work orderShipment lot, dates, quantities and part revision
Work order to inputsMaterial issues, split/mixed lots, consumption and yield
Inputs to plant receiptsReceipt lot, seller/producer identity and transport reference
Receipts to upstream productionPurchase and production records connecting the material to its actual source
Document chainConsistent names, quantities, dates and a custodian who can explain differences

Screen the entity, retain the version

Use the DHS UFLPA Entity List for the current names and notice references. Save when the check occurred and which alias or address caused concern. A similar name needs investigation; a name absent from the list cannot establish that every upstream material is outside the law’s reach.

Put the gap in supplier qualification

Use the supplier qualification exercise to request a redacted sample trail before an award. Assign an owner and deadline for missing records, and reopen the check when the material source changes. Keep confidential production records in the parties’ approved channel. For a detention or other formal action, route the notice and the indexed evidence to the importer’s qualified adviser.

Continue with your records

Walk one lot through the supplier qualification checklist

Official sources and review scope

Source check 2026-11-12. This editorial guide organizes questions and records for a Mexico–US transaction. Confirm the rules, effective dates and facts with the responsible importer and qualified professionals before filing or committing goods.