What is chain of custody evidence under UFLPA?

Chain of custody evidence shows an unbroken path of materials from source to finished goods. Typical records include certificates of origin, bills of lading, commercial invoices, production and inventory logs, facility-level details (addresses, ownership), supplier attestations, and any intermediary processing documentation that verifies origin and handlers. Parakeet links these to specific parts, facilities, and shipments for audit-ready traceability.

What is a UFLPA dossier?

A UFLPA dossier is a compiled evidence package used to rebut the forced-labor presumption. It typically includes an N-tier parts→facility→supplier map, region-of-origin analysis, watchlist screening results, supplier affidavits, shipping and transactional documents, and a time-stamped audit trail. Parakeet’s Rosella AI assembles these artifacts into a repeatable, case-based packet for CBP reviews.

UFLPA alerting and N‑tier exposure detection

Published: 2025-09-08

Executive summary

Parakeet Risk detects UFLPA exposure across direct and sub-tier suppliers, issues configurable alerts, and assembles audit-ready evidence with Rosella AI. Built for industrial teams, it links parts, facilities, suppliers, and shipments into a single, actionable graph—so you can route cases, collect attestations, and respond consistently to CBP inquiries.

What you get: N‑tier mapping, watchlist screening, case workflows, and repeatable dossier generation.
Built for how you work: Enhances existing Excel/QMS exports and integrates with tools like Trello and Slack for faster triage.
Learn more: Explore related capabilities on our Features, Rosella AI, and Packaging/TPRM pages.

How it compares

Capability	Parakeet Risk	Point watchlist screeners	Standalone traceability tools	Spreadsheet‑only approach
N‑tier mapping depth	Parts → facilities → suppliers → parent entities in one graph	Entity name checks only	Material/lot focus; limited watchlist context	Manual joins; brittle lookups
Evidence packet generation	Case-based UFLPA dossiers with templates and audit trails	Exports lists; no packet assembly	Document storage; manual compilation	Fully manual, error‑prone
Workflow and routing	Built‑in tasks, reviews, and escalations; Trello/Slack integrations	Alerts without case workflows	Project-centric tasks; limited compliance routing	Email- and sheet‑driven
Excel synergy	Ingests existing spreadsheets; preserves structure with validation	CSV import/export only	Imports accepted; reformatting often required	Native, but no controls/audit
Alerting and case management	Configurable rules and sub‑tier signals create reviewable cases	Single‑entity hit notifications	Process events; fewer sanctions/UFLPA signals	None beyond filters
Traceability + screening context	Links BoM, shipments, attestations, and watchlists	Screening only	Traceability only	Fragmented across tabs
Audit trail	Time‑stamped artifacts and decisions per case	Limited logs	Activity logs vary	Version history only
Total cost of ownership	Unified platform for mapping, screening, and evidence	Add‑on to other tools needed	Add‑on screening or workflows needed	High manual burden

Parakeet Risk now helps industrial teams spot Uyghur Forced Labor Prevention Act (UFLPA) exposure across direct and sub‑tier suppliers, with automated alerts and audit‑ready evidence generation via our Rosella AI Agent. This release strengthens our Supply Chain Resilience solution for manufacturing, pharma, and consumer goods brands.

New: Download a sample CBP rebuttal/detention response packet (templates + checklist) to see how Parakeet assembles evidence.

Download: Sample CBP packet

See: TPRM for material traceability and UFLPA

What’s inside: cover‑letter template, chain‑of‑custody log, supplier affidavits, part‑to‑facility BoM mapping, and a shipping‑docs index.

CBP dossier checklist (download)

Use this one-page checklist to prep a CBP rebuttal/detention response with repeatable evidence packets:

Cover letter and executive summary mapping parts → facilities → suppliers
Region-of-origin analysis and risk rationale (XUAR/entity-list checks)
Chain of custody: certificates of origin, bills of lading, invoices, production and inventory logs
Facility identifiers: addresses, ownership, and parent/affiliate links
Supplier attestations and certifications (versioned)
Shipment artifacts: ASNs, packing lists, HS codes, routing and transshipment notes
Audit trail: reviewer decisions, timestamps, and corrective actions

Download: CBP dossier checklist

Why it matters

Under UFLPA, CBP applies a rebuttable presumption: goods mined, produced, or manufactured wholly or in part in Xinjiang (XUAR) or by an entity on the UFLPA Entity List are presumed made with forced labor, requiring clear and convincing evidence to rebut. The presumption can apply even when goods ship from outside China if any input traces back to XUAR or a listed entity.

What’s new in Parakeet Risk

Automated UFLPA alerting: flag suppliers and parts that match listed entities or high‑risk regions; route cases to workflows your team controls.
N‑tier exposure detection: map and monitor dependencies several tiers deep (parts → facilities → suppliers → parent entities) to reveal hidden risk paths.
Evidence fast‑track: generate documentation packets and audit trails to support applicability reviews or rebuttal submissions when CBP inquiries arise.

How N‑tier exposure detection works

1) Ingest what you have: spreadsheets, QMS exports, PO/ASN feeds, and certifications—no need to abandon existing Excel processes. 2) Build the graph: Parakeet links parts, suppliers, facilities, and regions; Rosella AI normalizes aliases and resolves entity names. 3) Cross‑check: the graph is screened against selected watchlists and region rules; hits create tasks in your unified workflow. 4) Prove it: attach supplier attestations, shipping docs, and chain‑of‑custody evidence to each case for rapid, repeatable audits.

Sub‑tier mapping notes

Trace inputs for commodities with heightened scrutiny (e.g., cotton, tomatoes, and polysilicon inputs used in solar supply chains).
Capture facility‑level data (addresses, ownership, and parent/affiliate links) to avoid false positives from look‑alike names.
Watch for transshipment routes that may obscure origin; validate intermediate processors and raw‑material sources.
Maintain versioned attestations and certifications; re‑screen upon supplier changes or regulatory updates.

Watchlists you can screen against

Use Parakeet’s configurable screening to include one or more of the following:

UFLPA Entity List (Forced Labor Enforcement Task Force, DHS).
OFAC Specially Designated Nationals (SDN) and non‑SDN consolidated lists (U.S. Treasury).
BIS Entity List (U.S. Department of Commerce).
United Nations Security Council Consolidated List.
European Union consolidated financial sanctions resources.

Example signals our graph detects

Signal	Examples	Typical action
Listed‑entity match	Supplier, facility, or parent on UFLPA Entity List	Create hold task; request applicability evidence; notify sourcing
Region‑of‑origin risk	Input traced to XUAR via upstream processor	Escalate to compliance; initiate alternative sourcing
Document inconsistency	Mismatch across C/O, BOL, and supplier attestations	Trigger Rosella AI review; request corrected docs

See it in action (2‑minute demo)

Get started

Explore the capabilities inside Supply Chain Resilience.
Review steps and evidence expectations in our UFLPA guide.
Want tailored screening and mapping? Contact us to enable watchlists and import your sub‑tier data.