2026 working guide · source to draft
A controlled CBP forced-labor evidence package checklist.
A practical architecture for searchable, indexed, translated, nonduplicative evidence—without asking software to decide legal sufficiency or submit externally.
The seven rails
Make every conclusion reviewable.
The objective is not more documents. It is a record in which every extracted fact, translated statement, relationship, issue, and exhibit can be followed back to its source.
Pin the professional-selected path
Record the authority, process, triggering notice, dates, timezone, and calculation basis. Software may calculate from a pinned rule; it should not choose the legal path.
Preserve the source inventory
Keep immutable originals, receipt times, filenames, page counts, detected file types, SHA-256 checksums, quarantine reasons, and supersession links.
Trace every claimed transition
Connect product, input, supplier, facility, production, transaction, payment, and shipment relationships only when a source page supports the edge.
Pair original and translated text
Keep the original beside the translation, identify language and method, preserve page linkage, and require human review when confidence is low.
Find conflicts before compilation
Review missing records, duplicates, contradictions, unsupported transitions, and quantity, date, or entity mismatches as quality observations—not legal conclusions.
Hold exhibit numbers stable
Assign exhibit numbers once, record relevance, and preserve a manifest and checksum index so later revisions do not silently renumber the record.
Require named professional approval
Block export until required decisions are recorded. Label the result approved for export by that reviewer, never approved by CBP or externally submitted.
What belongs in the source inventory?
Exact requirements differ by authority, process, commodity, and notice. Use this as an operational map; the professional reviewer decides which records matter and what showing applies.
Authority and process
Professional-selected authority, review path, governing notice, confirmed trigger, due date, rule version, and calculation basis
Parties and facilities
Legal names, addresses, ownership, roles, site identifiers, production locations, and source-page citations
Materials and production
Product, inputs, sub-tier suppliers, production stages, quantities, dates, capacity, and links between each transition
Transactions and payments
Purchase orders, invoices, contracts, transport records, payment records, and quantity or date reconciliation
Labor and control records
Applicable labor documentation, policies, audits, worker records, or remediation evidence selected by the professional
Package controls
Translations, relevance statements, stable exhibits, issue resolutions, manifest, checksums, approval record, and export receipt
What evidence software can do
Preserve originals and checksums.
Extract and pair text with source pages.
Organize entities and evidence-supported relationships.
Surface quality findings and record human resolutions.
Compile a stable, searchable draft behind approval.
What it must not claim
That evidence is legally sufficient or admissible.
That a supply chain is forced-labor free.
That a translation or source record is true.
That CBP will accept the package or release cargo.
That the software submitted anything externally.
Use the guide
Start free. Audit one defined chain when the workflow is real.
The checklist captures no confidential evidence. A readiness audit begins only after organization, role, authority, timing, scope, and access are reviewed.