COMPLIANCE NEWS / JULY 28, 2026

Forced-labor compliance and supply-chain traceability.

American Spinning Works and Berry Blanks will operate a documented, traceable, and forced-labor-free supply chain designed to protect market access, reduce customs risk, and strengthen customer confidence.

Important: This operating policy is not legal advice. The final program and contractual language should be reviewed by qualified U.S. and Guatemalan trade counsel and updated as official rules, entity lists, and customs guidance change.

01 / SHARED COMMITMENT

Controls aligned across both companies.

The companies’ controls will align with the U.S. Uyghur Forced Labor Prevention Act, U.S. Customs and Border Protection guidance on importer responsibility and due diligence, Guatemala Ministerial Agreement 377-2026, and applicable forced-labor restriction lists recognized by U.S. or Guatemalan authorities.

Screening, audits, documentation, training, traceability technology, and record retention are treated as market-access investments that reduce detention, penalty, customer-loss, and supply-interruption risk.

02 / RESPONSIBILITIES

Two control points, one chain of custody.

UPSTREAM

American Spinning Works

Approve and screen suppliers; document input origin and transaction history; connect incoming fiber to yarn batches; prohibit undocumented or restricted sources; and preserve commercial and production evidence.

Customer value

Traceable yarn supported by a structured evidence package.

DOWNSTREAM

Berry Blanks

Buy only from approved sources; connect finished orders to production and shipment records; prevent unauthorized subcontracting; and prepare shipment-level traceability packages.

Customer value

Responsibly sourced, traceable blanks documented from material origin through export.

03 / TRACEABILITY PATH

Every handoff needs evidence.

01Raw-material source

02Fiber lot

03Yarn batch

04Fabric lot

05Dye / finish batch

06Cutting & sewing order

07Finished-goods lot

08Export shipment

A traceability claim is not complete when it relies solely on a supplier declaration. Each link requires commercial and production evidence.

04 / GOVERNANCE

Screen, document, escalate.

Assign a compliance owner at each company.
Review restricted-entity lists before onboarding and periodically thereafter.
Re-screen parties before high-risk purchases or shipments.
Conduct risk-based supplier reviews and audits.

Train purchasing, production, logistics, sales, and documentation personnel.
Escalate missing or suspicious documents before production or shipment.
Suspend purchases when suppliers cannot demonstrate origin or conditions.
Review the program annually and whenever applicable rules change.

05 / IMPLEMENTATION

Seven immediate priorities.

01Map every supplier, processor, subcontractor, and production location.

02Establish a shared supplier-approval and restricted-party screening process.

03Define lot and batch identifiers that connect both companies’ records.

04Create standard supplier declarations and contractual compliance clauses.

05Build a shipment-level document checklist and traceability dossier.

06Test the system by tracing a sample shipment back to its raw-material source.

07Correct evidence gaps before representing products as fully traceable.

DOCUMENTATION-READY SOURCING

Bring us the requirement.

Share the product, sourcing criteria, shipment timing, and documentation needs. We’ll organize the available chain-of-custody evidence and identify gaps requiring further review.

Start an RFQ ↗