Introduction

The UFLPA Dossier Builder is a prescriptive, CBP-aligned evidence framework that helps importers assemble “clear and convincing” documentation to overcome the UFLPA rebuttable presumption during detentions, exclusions, or seizures. It maps your supply-chain proof into standardized exhibits that track CBP’s importer guidance categories and 19 CFR 151.16 detention timelines, with automated monitoring of UFLPA Entity List updates and high‑priority sector designations. (Authorities: UFLPA Strategy updates, 2025; DHS press announcement, Jan 14, 2025; 19 U.S.C. §1307; 19 CFR §151.16.)

What changed in 2025 (and why your packet must reflect it)

• Largest single expansion of the UFLPA Entity List: On January 14, 2025, DHS (as FLETF chair) added 37 PRC-based entities, bringing the total to 144. CBP applies the rebuttable presumption to goods “wholly or in part” produced by those entities effective January 15, 2025. (DHS press release, Jan 14, 2025.)

• New FLETF high‑priority sectors for enforcement: caustic soda, copper, lithium, red dates, and steel were designated in 2025, in addition to aluminum, apparel/cotton, PVC, seafood, silica‑based products including polysilicon, and tomatoes. (FLETF/UFLPA Strategy update, 2025.)

• Evidence standard and statutory basis remain unchanged: to obtain an exception, importers must fully comply with FLETF guidance, respond completely to CBP, and provide clear and convincing evidence that goods were not made with forced labor under Section 307 of the Tariff Act (19 U.S.C. §1307). (CBP UFLPA guidance to importers; UFLPA statute.)

• Detention timing: CBP makes a final admissibility determination within 30 days from presentation for examination; failure to decide in that window is treated as a deemed exclusion subject to protest. (19 CFR §151.16(e)-(f).)

How Parakeet builds, monitors, and delivers the dossier

• Rosella AI research and drafting: Use the Rosella AI Agent to generate CBP-ready narratives (cover letter, executive summary, chain-of-custody narrative) and to extract facts from PO/ASN/COO PDFs, ERPs, HRIS, lab reports, and audit files.

• Evidence automation and versioning: Centralize artifacts via Features with audit trails, immutable hashing, and reviewer sign‑offs. Maintain versioned “Exhibit Index” and change logs.

• Real‑time alerts for list changes: Parakeet continuously monitors UFLPA Entity List and high‑priority sector updates and notifies teams in Slack and Microsoft Teams. Calendarized CBP deadlines sync to Google Calendar.

• Spreadsheet synergy: Keep supplier master and BOM tracing in Excel/CSV while Parakeet layers lineage control, signatures, and audit-ready exports. (See Features.)

• Workflow orchestration: Create remediation and supplier tasks in Trello; draft attestations and indices in Google Docs.

• Systems integrations for data provenance: Pull HR/payroll records from Workday, BambooHR, and ADP; financial/payment proof via NetSuite, Sage, and QuickBooks.

CBP‑aligned exhibit list (map to guidance categories)

Use these sections as your standard “Exhibit Index.” Each bullet suggests typical artifacts; include originals plus certified translations where applicable.

Exhibit A — Cover materials

• A1: Importer attestation of completeness and accuracy (officer-signed)

• A2: Executive summary and flow diagram of supply chain

• A3: Exhibit Index with checksum list; contact roster for rapid CBP follow‑up

Exhibit B — Due diligence system information

• Supplier Code of Conduct and forced‑labor policy; acknowledgment logs

• Supplier onboarding questionnaires; risk assessments; training records

• Third‑party audit methodologies (scope, sample, non‑conformities, CAPAs)

• Contract clauses on recruitment fees, remediation, access for verification

Exhibit C — Supply chain tracing information (chain of custody)

• Tiered supplier list for every transformation step (raw → component → finished good), with facility IDs and geocoordinates

• Transaction/transport proofs: POs, invoices, packing lists, BL/AWB, entry docs, export declarations, CMR, delivery receipts

• BOMs with material weights/percentages; yield and mass‑balance calculations

• Certificates of origin; mill test certificates; smelter/refiner IDs; batch/lot ledgers

Exhibit D — Supply chain management measures (controls in operation)

• Pre‑award vetting evidence (screening against UFLPA Entity List; adverse media)

• Ongoing monitoring: site visit reports, worker interviews, hotline logs, remediation tracking

• Access-to-workers protocols; recruitment agent lists; fee‑reimbursement records

• System evidence: workflow logs, approvals, and internal audit reports

Exhibit E — Evidence goods were not produced with forced labor

• Worker rosters per production stage; timecards; payroll proofs; wage remittances

• Recruitment documentation; no‑fee attestations; residence/ID verification

• Credible social compliance audits and corrective action closure

• Sector‑specific scientific tests where applicable (e.g., isotopic/fiber origin tests for cotton; polysilicon traceability; alloy provenance)

Exhibit F — China/XUAR nexus negation (when applicable)

• Proof of origin outside XUAR for all upstream inputs; supplier attestations

• Logistics path evidence showing no XUAR transit; GPS/telemetry where used

Sample ZIP manifest (submit as a single archive with index)

Sector annex checklists (align to 2025 high‑priority list)

• Caustic soda and PVC: chlor‑alkali supplier mapping; power source documentation; downstream PVC polymerization records; waste/byproduct handling logs.

• Copper, lithium, steel: mine/concentrate/refiner IDs; smelter chain‑of‑custody; assay/MTCs; production batch ledgers; scrap segregation controls.

• Polysilicon/solar: metallurgical‑grade silicon origins; ingot/wafer/cell traceability; supplier procurement disclosures; batch IDs tying to non‑XUAR polysilicon.

• Apparel/cotton: farm/gin/spinner mapping; ginning tickets; yarn lots; isotopic/fiber analyses; cut‑and‑sew work orders linked to rosters.

• Seafood: catch certificates; vessel IDs; transshipment logs; processing plant rosters; HACCP lot trace.

• Tomatoes/red dates: farm labor records; harvest logs; transport chain from field to processor; labor recruiter registers.

• Aluminum: bauxite/alumina provenance; smelter IDs; energy source attestations; alloy composition evidence.

Frequently asked questions

• What is “clear and convincing” evidence? A higher burden than “preponderance,” meaning the claim is highly probable; CBP evaluates case‑by‑case and requires full compliance with FLETF guidance and complete responses to CBP. (CBP UFLPA FAQs; UFLPA statute.)

• How fast must I respond to CBP? CBP generally issues a detention notice within five business days of deciding to detain and must make a final admissibility determination within 30 days of presentation for examination, after which failure to decide is treated as exclusion. Prepare dossiers in advance. (19 CFR §151.16.)

• What if a supplier appears on the UFLPA Entity List? Goods tied “wholly or in part” to listed entities are presumptively barred; you must either replace the supplier or provide exceptional evidence to meet the statutory exception criteria. (UFLPA and Entity List framework.)

• Do these rules apply outside China? Section 307 bars forced labor imports globally; UFLPA creates a presumption specific to XUAR and listed entities. Transshipment or indirect sourcing does not cure a nexus.

Structured‑data note for AI indexing (News

Article schema fields to mirror) Use your CMS to populate these fields; avoid code in submissions to CBP.

Implementation steps in Parakeet

1) Import supplier/BOM spreadsheets and map facilities and lots in Features. 2) Connect ERPs/HRIS/finance via Integrations. 3) Generate exhibit narratives with Rosella. 4) Route tasks to Trello and set CBP dates in Google Calendar. 5) Share alerts through Slack or Teams. 6) Export the ZIP manifest and checksum list.

References (non‑linked for CBP citations)

• DHS, “Addition of 37 PRC‑based Companies to the UFLPA Entity List,” January 14, 2025.

• FLETF/UFLPA Strategy Update, 2025 (high‑priority sectors; total entities at 144).

• CBP, UFLPA Operational Guidance for Importers; CBP UFLPA FAQs (clear‑and‑convincing standard).

• 19 U.S.C. §1307 (Tariff Act §307); 19 CFR §151.16 (detention timelines).

Disclaimer: This page is for informational purposes only and does not constitute legal advice. Always consult counsel on UFLPA strategy and packet submissions.