CBP Publication No. 3082-0223

Office of Trade

Guidance on Executive Summaries and Sample Tables of Contents:
Preparing a UFLPA Applicability Review Submission

The outline below provides guidance on executive summaries and sample tables of contents for importer applicability
review submissions—i.e., the document submission that an importer may present to Customs and Border Protection(CBP) to demonstrate that a shipment is not subject to the Uyghur Forced Labor Prevention Act (UFLPA) because themerchandise was not produced in whole or in part in the Xinjiang Uyghur Autonomous Region (XUAR) or by an entity on
the UFLPA Entity List. This outline is not intended to serve as an exhaustive list of documentation that CBP may
request; it identifies documents that typically facilitate CBP’s review and should be included in importer submissions.
Generally, to demonstrate that the UFLPA does not apply to a shipment targeted for examination under the law,
importers will need to provide documentation produced in the ordinary course of business that details the order,purchase, manufacture, and transportation of inputs throughout their supply chain. CBP considers the totality ofinformation provided by an importer in assessing the admissibility of merchandise.
All documents provided should include translations into English.

EXECUTIVE SUMMARY
Each package of documents should be well organized and include an Executive Summary explaining the documents
contained in the package. The Executive Summary should include the following:
1) Annotated document list. An index of the documents provided that may be in a spreadsheet or other format. It
should list each document included in the package according to supply chain level, as well as a brief explanationof the purpose of the document. In some cases, importers may want to explain the significance of the document
or highlight the relationship of that document to others in the package. It may be helpful to mention key pieces ofinformation shown on a document, such as a purchase order number, contract number, or other relevant data.
Documents should be numbered for ease of reference.
2) Summary of supply chain. The Executive Summary should include key information that connects each step in thetransportation and manufacturing processes, such as detention number, entry number, bill of lading number,container numbers, contract numbers, purchase order numbers, production or work order numbers, and otherrelevant information. This information may be provided in a spreadsheet or other type of document that illustrates
the flow of the supply chain across each level.
3) Additional summary information. Additional context or other information that the importer believes will be helpful
for CBP to understand the documentation provided. For example, an importer could create a slide deck that
includes each document with the key information highlighted and annotated. An importer could also include atracing report that summarizes all manufacturing processes along with a list of vendors and a list of relevantbusiness transactions involved with the detained shipment, such as a purchase order number, contract number,or production number.

SAMPLE TABLES OF CONTENTS
The below sample tables of contents may assist importers in providing the types of documents that could facilitate
CBP’s applicability determination, i.e., determining whether the UFLPA applies to an importation. Please note: As inthe example for solar panels below, importers may wish to organize the table of contents based on the different stepsof the supply chain where one or more steps involve multiple suppliers.

Generic Sample Table of Contents: Documents for All Suppliers
I. Executive Summary
II. Documents Demonstrating the Parties Participating in the Transaction
a. Invoiceb. Purchase Orderc. Production Contract
d. Work OrderIII. Documentation Relating to the Payment and Transportation of Raw Materials
a. Bill of Lading
b. Foreign Customs Clearancec. Declaration Forms and Waybills
d. Transportation Recordse. Manifest
IV. Transaction and Supply Chain Records
a. Proof of Payment
b. Certificate of Originc. Packing List
d. Bill of Ladinge. Manifest
Sample Table of Contents for Solar Panels
I. Executive Summary
II. Imported Modules/Module Producers
a. Invoice and Packing List
b. Bill of Ladingc. Entry Summary
d. Shipping and Freight Arrival Noticee. Module Supplier Certificate of Origin
f. Purchase Orderg. Work Orderh. Production Contract
i. Solar Module Production Records
j. Solar Cell Inbound & Outbound Records
III. Solar Cell Suppliersa. Production Steps Flow Chartb. Purchase Orderc. Commercial Invoice and Packing List
d. Bill of Ladinge. Work Orderf. Production Contract
g. Cell Production Records
h. Wafer Inbound & Outbound Records
i. Solar Cell Certificate of Origin
j. Proof of Payment
k. Foreign Customs Clearance Documents
IV. Wafer Suppliersa. Purchase Orders
b. Commercial Invoice and Packing List
c. Bill of Lading
d. Work Ordere. Production Contract
f. Wafer Production Records

g. Ingots Inbound & Outbound Records
h. Wafer Seller Certificate of Origin
i. Proof of Payment
j. Foreign Customs Clearance Documents
V. Ingot Suppliersa. Purchase Orders
b. Production Contractsc. Commercial Invoices
d. Packing Lists
e. Certificate of Originf. Delivery Orders
g. Proof of Payment
h. Declaration Forms and Waybills
i. Ingot Production Records
j. Polysilicon Inbound & Outbound Records
k. Foreign Customs Clearance Documents
VI. Polysilicon Suppliersa. Purchase Orders
b. Production Contractsc. Commercial Invoices
d. Packing Lists
e. Certificate of Origin
f. Delivery Orders
g. Proof of Payment
h. Declaration Forms and Waybills
i. Polysilicon Production Records
j. Silicon Inbound & Outbound Records
k. Foreign Customs Clearance Documents
VII. Metallurgical Grade Silicon Suppliersa. Purchase Orders
b. Commercial Invoicesc. Payment Receipts
d. Bills of Ladinge. Transportation Records
f. Records of Batch Numbers and Production Dates
g. Quartzite Inbound & Outbound Records
h. Proof of Payment
i. Foreign Customs Clearance Documents
VIII. Quartzite Suppliersa. Purchase Orders
b. Commercial Invoicesc. Proof of Payment
d. Transportation Records
e. Unredacted name, address/location of minef. Quartzite mining records
g. Foreign Customs Clearance Documents

This sample document is for illustrative
purposes only and does not represent theentirety of what information CBP might
require to be submitted for a particularimportation. It is not intended to replace,supersede, or in any way modify any
applicable laws, regulations, or policies orimporter responsibilities pursuant to suchlaws, regulations, or policies pertaining to
the importation of goods or merchandise
into the United States. It is not intended to
be prescriptive, as supply chains vary
dramatically across industries, betweencompanies, and even within the samecompany.
Furthermore, nothing in this document
affects CBP’s ability to exercise its legal
authorities pursuant to any laws CBP ischarged with administering or enforcing inparticular cases.