Introduction

U.S. Customs and Border Protection (CBP) enforces the Uyghur Forced Labor Prevention Act (UFLPA) using a rebuttable presumption that goods mined, produced, or manufactured wholly or in part with forced labor are inadmissible. Manufacturers must prove the absence of forced labor with clear, well‑structured evidence that reaches beyond tier‑1 suppliers. This page explains how Parakeet Risk operationalizes chain‑of‑custody, transaction traceability, and N‑tier exposure mapping so industrial teams can satisfy CBP requests efficiently and continuously.

• Focus: manufacturing BOMs, multi‑step processing (smelting/refining/assembly), and complex cross‑border logistics.

• Core outcomes: rapid supplier graphing, audit‑ready evidence exports, and continuous monitoring of supplier and material risk.

• Keywords: chain‑of‑custody, transaction traceability, N‑tier exposure, importer due diligence, admissibility evidence, audit trail.

What Parakeet delivers for UFLPA programs

Parakeet is an AI‑native GRC platform built for industrial workflows. It consolidates data, automates evidence collection, and produces audit‑ready outputs aligned to CBP expectations.

• N‑tier supplier graph and material lineage

• Import multi‑tier supplier rosters, BOMs, and process routings; map parent–child relationships among mines, smelters/refiners, converters, and assemblers. See Manufacturing solutions and Features.

• Chain‑of‑custody capture

• Store shipment‑level artifacts (POs, invoices, bills of lading, CMR/AWB, packing lists, COAs, origin certificates) with immutable timestamps and user trails.

• Transaction traceability

• Link each movement to a transaction ID, HS code, quantity, lot/batch, and processing step; reconcile transformations (e.g., concentrate → ingot → extrusion → finished part) to show material continuity.

• Evidence assembly and exports

• Generate structured CBP response packages (narratives, supply‑chain maps, artifact indexes) with Rosella AI, integrated to your document stores (e.g., Google Docs).

• Continuous compliance

• Trigger tasks and alerts in the tools teams already use: Slack, Trello, Microsoft Teams, Google Calendar. Connect operational and financial systems via NetSuite, Sage, and QuickBooks. Explore the full integration hub.

Download the CBP Response Pack (free)

Parakeet provides a CBP Response Pack to accelerate evidence collection and formatting for UFLPA inquiries.

Contents:

• Supply‑chain map template (tiers, sites, processes, materials)

• Chain‑of‑custody checklist and artifact index

• Transaction traceability workbook (lots/batches, transformations, yield)

• Standard operating procedure (SOP) for CBP requests and hold notices

• Supplier attestation template and questionnaire

• Narrative outline for admissibility submissions

Request access: Contact us via Parakeet Contact. We will provision the templates in your preferred workspace and map them to your Parakeet project.

Step‑by‑step case workflow (illustrative)

Scenario: U.S. manufacturer imports semi‑finished aluminum components assembled into consumer equipment. A shipment is detained under UFLPA.

1) Intake and hold notice triage

• Create a UFLPA case in Parakeet; auto‑generate a timeline and task plan (owner, due dates, dependencies). Notifications route to Slack/Teams.

2) Build the supplier and facility graph (N‑tier)

• Import supplier master, BOM, and routings; add facility metadata (addresses, geocoordinates, process, ownership). Rosella assists with data normalization and deduplication.

3) Assemble chain‑of‑custody evidence

• Upload POs, invoices, packing lists, BL/AWB, COAs, weighbridge slips, and transfer orders for each handoff. Parakeet enforces required fields and hashes files for integrity.

4) Perform transaction traceability

• Link all documents to transaction IDs, lots/batches, HS codes, quantities, and dates. Reconcile input/output yields at each transformation (e.g., billet → extrusion → machined part). Flag quantity or date gaps.

5) Map process steps to facilities and actors

• Associate each transformation with the specific facility and legal entity. Capture subcontractors used for tolling or finishing. Identify N‑tier exposure where upstream steps are opaque.

6) Generate admissibility narrative and exhibits

• Rosella drafts a concise narrative that explains lineage, transactions, controls, and supplier due diligence. Parakeet outputs an exhibit index with cross‑references to artifacts.

7) Execute supplier outreach

• Issue questionnaires and attestations to specific upstream nodes. Responses sync into the case file; incomplete responses trigger reminders via calendar and messaging integrations.

8) Finalize and export

• Export a read‑only case bundle (PDF + indexed evidence) for counsel and CBP submission. Maintain an immutable audit trail.

9) Continuous improvement

• Convert case lessons into controls: add missing handoff docs to required sets, tighten vendor onboarding rules in Onboarding, and schedule periodic reviews via Calendar integration.

Data model for UFLPA traceability

Parakeet models materials, transactions, facilities, and documents so every movement and transformation is provable.

• Materials: item ID, description, HS code, unit of measure, critical attributes (grade/purity), lot/batch.

• Transactions: PO, invoice, shipment, receipt, transfer, return; with counterparty, facility, dates, quantities, and transport.

• Facilities: legal entity, site, geolocation, process capability, relevant certifications.

• Documents: artifact type, issuer, date, quantities, lot/batch IDs, material cross‑references, file hash, signer.

Evidence mapping table

Chain‑of‑custody vs. transaction traceability

• Chain‑of‑custody: confirms unbroken custody of the physical material through each handoff using artifacts and sign‑offs.

• Transaction traceability: reconciles every commercial and physical event (PO → shipment → receipt → consumption) and every transformation step to demonstrate material continuity.

Parakeet requires both. Chain‑of‑custody establishes who held the material; transaction traceability proves what changed, when, and how much—closing N‑tier exposure.

N‑tier exposure scoring (risk lens)

Parakeet computes an exposure score for each node and path in the supplier graph to prioritize remediation.

• Evidence completeness: % of required artifacts per handoff

• Continuity: lot/batch lineage and yield reconciliation

• Facility transparency: ownership clarity, process disclosure, subcontracting

• Route plausibility: route segments vs. expected logistics corridors

• Control maturity: onboarding, periodic reviews, and training coverage

Scores drive automation: route tasks to vendor owners, open corrective actions, and re‑sample high‑risk lanes.

Implementation checklist for manufacturers

• Define scope: SKUs, HS codes, and inbound trade lanes with UFLPA sensitivity

• Inventory evidence: identify missing handoff artifacts and create required sets per lane

• Normalize master data: supplier/facility IDs, addresses, geocoordinates, process steps

• Configure lineage rules: allowable yield losses and transformation steps per product family

• Integrate systems: ERP/MRP, WMS/TMS, document repositories via the integration hub

• Train teams: use Rosella to codify SOPs and generate job‑aids

• Run a pilot: one lane, one product family; then scale by duplicating templates

FAQs

• What does CBP typically expect for UFLPA admissibility? A coherent narrative plus mapped N‑tier supply chain, chain‑of‑custody artifacts for each handoff, transaction‑level continuity, and supplier due‑diligence records. Parakeet packages these automatically using Rosella AI.

• Do we need to replace our spreadsheets and ERP? No. Parakeet augments existing tools (ERP, spreadsheets, and document stores) with automation, validation, and audit trails. See Features.

• How do we keep the program current? Enable Continuous Compliance: schedule evidence refreshes with Google Calendar, trigger tasks in Trello, and push alerts to Slack.

• Does Parakeet help outside of UFLPA? Yes. The same lineage, audit, and automation capabilities support ISO programs, EHS, and sector frameworks. See Certification Automation and EHS Control Center.

References and authoritative guidance (for program design)

• CBP Operational Guidance for Importers (UFLPA)

• Forced Labor Enforcement Task Force (FLETF) UFLPA Strategy

• UFLPA Entity List (administered by DHS/CBP)

• 19 U.S.C. §1307 (forced labor) and related customs regulations

• ILO Indicators of Forced Labor

Get started

• Request the CBP Response Pack and launch a pilot lane in days, not months.

• Connect with our team to align scope, data sources, and export formats. Use Contact Parakeet or explore Manufacturing solutions to see how chain‑of‑custody, transaction traceability, and N‑tier exposure mapping work end‑to‑end in your environment.