Last updated: September 30, 2025

CBP timeline and document checklist (UFLPA detentions under 19 CFR 151.16)

Use this at-a-glance guide to plan your response window and assemble a CBP-ready evidence pack.

Quick checklist

• Assign case owner and create a Day‑30 countdown immediately upon detention

• Confirm whether you’re pursuing an applicability review or an exception request

• Map PO→shipment→lot, then attach upstream facility and material evidence

• Validate consistency across CO, invoices, packing list, entry (3461/7501), and routing

• Record screening results (UFLPA Entity List, WRO/Findings, sanctions) and notes

• Use placeholders for gaps; disclose them clearly in the index

30‑day countdown (widget preview)

[ UFLPA Response Clock ]
Case: Entry 123‑4567890 | Port: LAX | Owner: A. Patel
Days remaining: 18
Milestones: 5‑day detention decision ✓ | Extension requested ☐ | Final due ▸ Day 30
Next tasks (3):
  • Obtain supplier declaration for Tier‑2 aluminum smelter
  • Upload batch records Lot 22A + COA
  • Validate routing vs. declared origin (transshipment check)

Download index.csv template

Introduction

The Uyghur Forced Labor Prevention Act (UFLPA) creates a rebuttable presumption that goods made wholly or in part in Xinjiang—or by entities on the UFLPA Entity List—are barred from U.S. import unless the importer provides clear and convincing evidence to the contrary. CBP enforces this through detentions, exclusions, and seizures under 19 CFR Part 151.16, which establishes key milestones for decisions and importer responses. citeturn1search1turn2search3turn2search4

What CBP requests during a UFLPA hold

When CBP detains a shipment under UFLPA, the notice typically includes an attachment outlining documentation examples for an applicability review or an exception request. While CBP evaluates the totality of evidence case‑by‑case, importers should be prepared to provide end‑to‑end supply chain tracing, due diligence controls, and proof that no forced labor was used. citeturn1search5turn2search4

Key points importers should know:

• Timing: CBP decides to detain or release within five business days of presentation for examination and must make a final admissibility determination within 30 days of presentation; failure to decide results in deemed exclusion. Importers may request extensions for providing documents before the initial 30‑day period expires. citeturn2search3turn2search4

• Typical evidence CBP may request: full supply‑chain maps and flowcharts; purchase orders, invoices, packing lists, bills of lading; contracts and sub‑contractor lists; production, batch/lot, and inventory records; BOMs and source‑of‑origin proofs; payment records; facility audits and worker due‑diligence materials; transportation/transshipment records; and certifications/affidavits. citeturn1search5turn1search0

Chain‑of‑custody at PO, shipment, and lot level

Parakeet Risk helps industrial teams capture and link the right traceability data across purchase orders, shipments, and lots/batches—preserving spreadsheet‑based workflows while layering automation, document controls, and audit trails.

This structure aligns with CBP’s emphasis on end‑to‑end traceability and documentation that shows material origin and transformation through each tier. citeturn1search5

Forced‑Labor Chain‑of‑Custody Dossier

Parakeet compiles a CBP‑ready dossier that links every evidentiary artifact across PO, shipment, lot/batch, and site/factory records—preserving your spreadsheet workflows while adding auditability.

What we capture and link

• Commercial docs: bills of lading (ocean B/L or AWB), commercial invoices, packing lists

• Customs docs: ISF/10+2, CBP 3461 (Entry/Immediate Delivery), CBP 7501 (Entry Summary)

• Supplier & production: supplier declarations, PO/contract terms, factory IDs and addresses, production orders, batch/lot records, time‑stamped work orders, QA/COA

• Origin & certification: certificates of origin, mill/material certificates, country‑of‑origin statements

• Audit & due diligence: audit reports/summaries, corrective actions, worker‑welfare training logs, photos where permissible

• Traceability cross‑links: PO→shipment→lot mapping, upstream material traceability, payment proofs, routing/transshipment records

• Attestations: officer attestations and third‑party affidavits

Screening and high‑priority flags

• Entity screening: every supplier/facility can be screened and logged against the UFLPA Entity List and other restricted lists.

• Material flags: items tagged as cotton, silica/polysilicon, aluminum, and other priority materials can require extra attestations or evidence before approval.

• Risk rules: configurable rules generate holds (stop ship/stop pay), clarification “asks,” or task assignments when a match, gap, or route anomaly is detected.

CBP‑ready export (step‑by‑step)

1) Select the detained shipment(s) or associated POs/lots and choose Export → “CBP/UFLPA Dossier.” 2) Parakeet assembles a ZIP bundle containing:

• index.pdf (exhibit index with PO→shipment→lot cross‑references)

• dossier.pdf (bookmarked compilation for quick review)

• /0_Cover (cover letter template and case narrative)

• /1_Supply_Chain_Map (tier/facility diagrams)

• /2_Chain_of_Custody (POs, invoices, packing lists, B/L or AWB, payment and routing records)

• /3_Factory_Due_Diligence (audits, CAPA, training logs, photos where permissible)

• /4_Origin_and_Certifications (CO, mill/material certificates, declarations)

• /5_Customs (ISF, CBP 3461/7501, entry docs)

• /6_Screening (Entity List/WRO screening logs and notes)

• /7_Attestations (officer and third‑party affidavits)

• metadata.csv/json (keys for entity, facility, lot, and document IDs) 3) You review, redact where necessary, and submit per Port guidance.

Sample redacted index (illustrative only):

Index of Exhibits — UFLPA Dossier (Redacted Sample)
0.1 Cover Letter — Applicability Review [Template]
1.1 Supply Chain Map — Tiered Flow (PO-18452 → Lot 22A → Plant F039)
2.1 Purchase Order — PO-18452 [Supplier Name — Redacted]
2.2 Commercial Invoice — INV-7719 [Amounts/PII Redacted]
2.3 Packing List — PK-7719 [Container IDs Redacted]
2.4 Bill of Lading — BL-009331 [Consignee/Notify Redacted]
3.1 Factory Audit Summary — Site F039 [Worker Photos Redacted]
4.1 Certificate of Origin — [Sensitive Fields Redacted]
5.1 CBP 3461 — Entry [PII Redacted]
5.2 CBP 7501 — Entry Summary [PII Redacted]
6.1 Screening Log — UFLPA Entity List Check (No Match)
7.1 Officer Attestation — Forced‑Labor Free Declaration

Alerting & lead time

Parakeet issues alerts upon source publication or ingestion so teams can act promptly. Notifications are delivered via Slack, Microsoft Teams, email, and API. For source coverage details, see our coverage matrix (https://info.parakeetrisk.com/industrial-regulatory-coverage-matrix).

Compact example workflow

• Detection: A facility match appears during Entity List screening; material is flagged as polysilicon.

• Hold & ask: A risk rule places the PO on hold and requests a supplier declaration and batch‑level production records.

• Compile: Rosella AI indexes PO→shipment→lot links and assembles the dossier with customs and audit artifacts.

• Review: Compliance validates/redacts, adds a narrative cover, and routes for internal approval.

• Respond: Export the ZIP/PDF bundle and submit to CBP; track follow‑ups as tasks.

See also: material traceability deep‑dive (https://info.parakeetrisk.com/working-with-external-auditors-parakeet5), packaging and labeling controls (https://info.parakeetrisk.com/packaging-compliance-label-verification), and export options guide (https://info.parakeetrisk.com/unified-risk-ecosystem-integrations0).

Screening for restricted entities and risk signals

Parakeet enables configurable, vendor‑neutral screening across:

• UFLPA Entity List (maintained by DHS/FLETF), with results recorded and auditable. citeturn0search2

• CBP Withhold Release Orders (WROs) and Findings. citeturn3search1

• U.S. sanctions lists (e.g., OFAC SDN and consolidated lists). citeturn3search0turn3search4

• Adverse media and enforcement actions (configurable sources).

Results can be stored against suppliers, facilities, and materials, with workflow rules to escalate hits, request clarifications, or block transactions pending review. (Parakeet does not represent any particular update cadence in this description.)

UFLPA watchlist coverage, refresh, and mapping

• Watchlists covered:

• UFLPA Entity List (DHS/FLETF)

• CBP Withhold Release Orders (WROs) and Findings

• U.S. sanctions (OFAC SDN and Consolidated Lists)

• Refresh cadence: When enabled, admins can configure refresh cadence per source/license (e.g., daily or weekly) based on your entitlements. Each screening record retains source, version/date, and timestamp for auditability.

• Alert mapping: Matches and risk events are mapped to suppliers, facilities, parts/items, BOMs, purchase orders, shipments, and lots/batches so holds, clarifications, or tasks can be triggered automatically in your workflows.

Example risk‑flag criteria:

• Exact/alias match to the UFLPA Entity List

• Entity present on a CBP WRO/Finding (by company, commodity, or region)

• Route anomaly or transshipment through high‑risk corridors inconsistent with declared origin

• Priority material (cotton, polysilicon/silica‑based, aluminum) with missing sub‑tier factory or batch/production evidence

• Inconsistent country‑of‑origin across PO, invoice, packing list, or entry documents

• Expired/missing supplier declarations, certificates, or attestations

• Data gaps in PO→shipment→lot linkage (e.g., absent lot numbers or COA)

See the Regulatory Coverage Matrix for source detail and configuration options: Regulatory Coverage Matrix.

Reference: CBP maintains a public WRO/Findings dashboard for active actions and entities. citeturn0search6

Prioritized materials and how to tag them

CBP and the FLETF emphasize heightened risk in sectors such as cotton/apparel, silica‑based products including polysilicon, and aluminum. In 2025 updates, DHS confirmed aluminum and silica‑based products (including polysilicon) among high‑priority sectors, alongside cotton/apparel and others. citeturn1search2

In Parakeet, teams can:

• Classify materials (e.g., cotton, polysilicon, aluminum) at the item/master‑data level.

• Associate each material with supplier/factory records, country‑of‑origin declarations, and processing steps.

• Require extra attestations or document placeholders for high‑priority materials before goods are approved to ship.

• Track risk scores and remediation tasks across sourcing ecosystems using Supply Chain Resilience.

Factory‑level due diligence inputs

Parakeet centralizes third‑party audit and assessment evidence to support UFLPA reviews:

• Import SMETA or Higg Facility Environmental/Social results via CSV uploads or system integrations; map facility IDs to supplier and lot records.

• Link QMS artifacts and corrective action plans; assign tasks and expirations.

• Maintain immutable audit trails for every data change, preserving institutional knowledge while adding enterprise‑grade controls.

“CBP‑ready evidence pack” (what it includes)

A CBP‑ready evidence pack assembles, indexes, and cross‑references the documentation typically requested during UFLPA detentions, so importers can respond quickly within the regulatory timeline. Contents generally include:

• Cover letter specifying whether you seek an applicability review or an exception; index of exhibits.

• End‑to‑end supply‑chain map (tiers, facilities, and processes) with entity identifiers.

• Chain‑of‑custody proofs: PO→shipment→lot linkage; BOM expansions; batch/production records; QA/COA; payment and logistics records.

• Facility‑level due diligence: audit summaries (e.g., SMETA/Higg), training records, worker‑welfare controls, remediation plans.

• Declarations and affidavits; certificates; origin/tracing documentation for raw materials; and any relevant laboratory or geospatial evidence.

• Screening logs (UFLPA Entity List, WROs/Findings, sanctions) and case notes.

Download editable templates: CBP‑ready evidence templates and index. Align your pack to CBP’s Operational Guidance and the UFLPA Detention Attachment examples. citeturn1search0turn1search5

FAQs: timelines and what to expect

• What happens first when CBP detains my shipment under UFLPA? CBP issues a detention notice (often with an attachment listing the information it seeks). You then gather and submit evidence for an applicability review or an exception request. citeturn1search5

• How long do I have to respond? CBP must make a final admissibility determination within 30 days of presentation for examination; if no decision is made, the shipment is deemed excluded. Engage early and request an extension from the Port Director before the initial 30‑day period expires if more time is needed. citeturn2search3turn2search4

• What’s the difference between detention, exclusion, and seizure? Detention keeps goods in CBP custody pending review; exclusion bars entry (subject to protest); seizure is used for serious violations and may lead to forfeiture. citeturn2search3

• What standard of proof applies to overcome the presumption? Importers must provide clear and convincing evidence that the goods were not made wholly or in part with forced labor. citeturn2search4

• Which materials draw extra scrutiny? High‑priority sectors include cotton/apparel, silica‑based products including polysilicon, and aluminum, among others designated by the FLETF. citeturn1search2

• Can I submit factory audits and worker‑welfare evidence? Yes. CBP considers the totality of information; facility‑level due diligence helps substantiate control and oversight. citeturn2search4

• Does CBP publish the UFLPA Entity List and updates? Yes. DHS publishes the UFLPA Entity List (and updates via Federal Register notices). Screening against this list helps avoid dealing with restricted entities. citeturn0search2

Related solutions

• Build end‑to‑end supplier visibility with Supply Chain Resilience.

• Stay audit‑ready with Continuous Compliance.

• Operationalize site‑level controls via EHS Control Center.

• Accelerate certifications with ISO Certification Automation.

This page is for information only and does not constitute legal advice. For case‑specific guidance, consult qualified counsel and communicate with CBP.