Supply-chain compliance
A chain that holds across tiers, spellings and quarters.
Supplier and shipment files that hold together across tiers, transliterations and a supplier list that changes every quarter.
the worked caseA smelter appears under three spellings across four tiers. The record keeps one entity, shows the three names it is known by, and dates each.
Two worked cases on this page, both fictional and both built the way a real one is: a value, the document it was read from, the date of reading, and the value it was chosen over.
The questions you get asked
Nobody asks for more information. They ask whether one line can be defended.
These are the questions that arrive after the work is delivered, from the party entitled to disagree with it. Every property on this page exists because one of them has to have an answer that does not depend on the person who assembled the file.
- 01
Show me the evidence for this shipment, down to the smelter.
- 02
This supplier is spelled three ways across your documents. Is that one facility or three?
- 03
Which declaration were you relying on when the goods were entered?
- 04
The declaration you relied on was withdrawn. What did you do about the entries that cited it?
Asked by a customs officer at the border, by a customer's responsible-sourcing auditor, and by an authority that starts from a presumption against you.
The buyer
Trade compliance, responsible sourcing and customs
Teams that must produce, per shipment or per supplier, a file that traces material back through tiers they do not contract with directly, under presumptions that put the burden on them.
What they fuse
Three kinds of source, one answer
Each kind arrives with different licence terms, different reader restrictions and different reasons to be wrong. The record keeps them distinguishable after the fusion, which is the part that is normally lost.
Questionnaires, bills of material, purchase records and audit reports supplied under confidentiality.
Customs, shipment and corporate-ownership subscriptions, frequently the only route to tiers beyond the first.
Entity and facility registers, enforcement and detention lists, published audits, transliterated official filings.
Worked case one
One facility, many namesOne smelter, three spellings, four tiers
The same facility appeared in supplier declarations, a licensed shipment dataset and a national register under three spellings and two corporate names. Matching them on string similarity would have been a guess. The record holds one facility, carries each name with the source and date it was observed, and marks the tier-three link as not found where no document supports it.
The figure beside this is what the reader sees: the value, its status, the source it was read from, and the value it was chosen over.
Worked case two
A source the supplier withdrewA declaration withdrawn in January, and the file that did not quietly change
Eleven weeks after submitting a country-of-origin declaration, a tier-two supplier wrote to withdraw it and sent a replacement naming a different smelter. Nothing was deleted. The withdrawn declaration is retained with the dates on which it was relied on, the replacement is a new entry with its own date, and every value downstream that cited the first is marked as resting on a withdrawn source. A file that silently corrects itself can no longer be reconciled with the entry it supported.
A different failure from the first case, on the same record and under the same four guarantees. Both are fictional; neither is a simplification of how the values are shown.
Why the record has to hold
What the rules ask for, in their own words
These are the recordkeeping obligations that make a defensible value a requirement rather than a preference. We name them because our customers are measured against them; we make no claim to certify anyone against any of them.
Rebuttable presumption on imports
United StatesGoods are presumed inadmissible unless the importer produces clear and convincing evidence, which in practice means a traceable supply-chain file down to raw material.
Due diligence and record retention
European UnionOperators must submit a due diligence statement, including geolocation of the plots of production, and keep the supporting documentation and risk assessments for five years.
Documented supply-chain due diligence
European Union and GermanyDue diligence must be documented internally, and under the German statute the documentation must be retained for at least seven years.
What changes for this reader
The same work, with the evidence attached at the moment it is read
Not a claim about speed and not a claim about savings: a description of the practice on each side. Everything on the left is what people in this role do today, and almost all of it is done well by people who resent having to do it that way.
Tier-two and tier-three links live in a spreadsheet keyed on supplier names as typed by whoever returned the questionnaire.
Each link cites the declaration, filing or dataset record it rests on, with the date it was observed.
One smelter under three transliterations is either three suppliers or one, decided by a similarity score nobody can defend to an officer.
It is one facility carrying all three names with their sources and dates, matched on a register identifier rather than a spelling.
A gap between tiers is filled with the most plausible origin, or left blank and read as though it were clean.
It is declared not found with what was searched and when, so the file cannot be mistaken for a complete chain.
When a supplier withdraws a declaration, the current file is corrected and the entries that relied on it are never revisited.
The withdrawal is a new entry, the withdrawn declaration is retained, and every value that cited it is marked as resting on a withdrawn source.
Producing the file behind an entry made last quarter means rebuilding it from this quarter's supplier list.
The file as submitted reproduces exactly, including the supplier list and the declarations as they stood that day.
What you get
What the record guarantees supply chain readers
The four guarantees, stated in the vocabulary of this sector. They are the same four everywhere; read them in general on the guarantees page, and see them applied to a live record on the demonstration.
- One record per supplier and per facility, with every transliteration and trading name kept and dated, and separate facilities never merged on a name.
- Every link in a chain cites the declaration, filing or dataset record it rests on, with the date it was observed.
- A tier or an origin that no document supports is declared not found, with what was searched, so the file cannot be read as a clean chain.
- The file submitted with a shipment can be reproduced later exactly as it was submitted.
Primary sources
The texts behind these obligations
Import presumptions, due diligence statutes and documentation duties now ask importers and operators to produce a traceable file. The primary texts and official guidance behind the obligations on this page are listed below. They are provided for reading, and naming them is not a claim that any record meets them.
- U.S. Customs and Border Protection. Uyghur Forced Labor Prevention Act. How the rebuttable presumption is enforced and what importers may be asked to show.
- Regulation (EU) 2023/1115 on deforestation-free products, EUR-Lex. Due diligence statements, geolocation and retention of documentation.
- European Commission. Regulation on deforestation-free products. The Commission's overview and guidance.
- Directive (EU) 2024/1760 on corporate sustainability due diligence, EUR-Lex. Due diligence duties and documentation.
- Lieferkettensorgfaltspflichtengesetz, section 10: documentation and reporting. Documentation to be kept for at least seven years (German-language statute).
Reference pages that apply to this sector
- Global Trade Item Number (GTIN)
- Global Location Number (GLN)
- Harmonized System (HS) code
- Economic Operators Registration and Identification (EORI)
- VAT identification number
- Legal Entity Identifier (LEI)
- Resolving identity by rule
- Declaring unknowns
- Blank cell vs declared unknown