Independent resource / Frameworks and practice
Supply-chain traceability, responsible sourcing and supplier evidence support questions about how goods were made. The EU and US frameworks answer distinct market and import questions.
Choose your framework
Begin with the relevant jurisdiction and legal basis. Then follow the practical records needed to examine the product's supply chain.
A product prohibition covering placing or making available on the EU market and exports. General application begins 14 December 2027; specified preparatory provisions apply earlier.
Use the EU investigation and decision framework. Do not import UFLPA's presumption into an EU assessment.
Read the EU frameworkThe general import prohibition applies beyond Xinjiang. UFLPA adds a rebuttable presumption for goods linked wholly or partly to Xinjiang or specified listed entities.
Keep WROs, Findings and UFLPA reviews distinct. Identify the legal basis of the actual shipment case.
Shared operational foundations
These practices help a reviewer reconstruct a product history. They are implementation methods, not a universal legal evidence checklist.
Connect contracting parties to upstream producers and processors.
Distinguish legal entities, registered offices and physical production sites.
Link inputs to extraction, growing and production stages.
Preserve identifiable handovers and transformation relationships.
Retain sources, review scope, contradictions and unresolved gaps.
A document may support movement, a transformation or a supplier relationship without establishing how workers were treated. Link the evidence layers through facilities and periods, and record what each source can actually support.
Responsible sourcing
Responsible sourcing and traceability connects purchasing decisions, supplier relationships and evidence review. A complete map helps locate a concern; it does not resolve that concern by itself.
| Question | EU framework | US framework |
|---|---|---|
| Market relationship | EU market placement and availability, and exports | Entry of imported goods into the United States |
| Starting legal mechanism | Product prohibition with risk-based investigation and decisions | Section 307 import prohibition; UFLPA adds a specific rebuttable presumption |
| Geographic perspective | Products regardless of origin, including EU production | Section 307 covers foreign production generally; UFLPA targets specified Xinjiang and entity links |
| Shared operating data | Supplier and facility identities, material relationships, custody events and supporting evidence | |
| Review outcome | Record the conclusion against the EU legal basis and procedure | Record the conclusion against the specific US legal basis and procedure |
Voluntary guidance and technical standards can inform the process. They do not replace either legal framework. The EU regulation expressly does not create additional due diligence obligations beyond those already in EU or national law (Article 1(3)).
Legal orientation checked on 4 October 2026. The practical workflow suggestions are independent editorial guidance. For an actual case, check the current law, official guidance and authority communication.
