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Building a Strong Product Passport

Product Passports let you put structured, validated information about a product in front of a border authority before your shipment arrives. This article explains what participation does and does not do, the baseline every passport should meet, and what a strong passport looks like for the use cases where guidance is most developed.

For the elements that make up a passport record, see What's in a Product Passport. To submit passports to a government partner, see Share Information with Governments.

Advisory content. The guidance and observations in this article reflect Altana's experience supporting importers leveraging Product Passports to collaborate with customs agencies (e.g. US Customs and Border Protection's Global Business Identifier Test) to date. They describe patterns, not commitments, and they do not predict the treatment of any individual shipment. Nothing here should be read as legal or customs advice.

The Premise

Product Passport submission to customs agencies is voluntary. Altana does not automatically submit Product Passports and users control what information is shared. A passport gives a border authority an earlier and richer view of a product than existing entry requirements demand, and it lets you show the standard-of-care work your compliance team already does. That is the core of it: earlier visibility, and a documented record of diligence.

It is important to understand that customs agencies are not transactional counterparties. Generally they do not operate on a "provide this data, receive this specific benefit" model. CBP, for example, retains full authority to examine, detain, or investigate any shipment at any time, regardless of what was submitted in advance. A Product Passport does not change that authority.

What a strong passport does is place your evidence of compliance with trade law in front of customs before the shipment arrives. That can support a low-risk determination on shipments that would otherwise attract scrutiny — which is how passports help importers avoid detentions, holds, and other enforcement actions.

Product Passports and the US Customs and Border Protection (CBP) Global Business Identifier (GBI) Test

CBP has allowed importers to submit Altana IDs on official filings to CBP as part of the GBI Test. The Altana ID corresponds to an Altana Product Passport which links a product to its verified value chain, and the supporting provenance and compliance information and documentation, enabling streamlined review by CBP and PGAs, efficient correspondence regarding any items of interest, and AI-based continuous monitoring to eliminate duplicate reviews if/when that product is imported in the future.

"GBI Test participants are at the forefront of change, informing customs adoption of supply chain traceability solutions to support a new era of trade. With an eye toward the future, GBI Test participants file identifiers to improve supply chain visibility, enable more efficient customs procedures, and benefit from more secure, streamlined trade operations" — CBP GBI Test, FAQ

Product Passport Best Practices for Working with Customs Agencies

Regardless of product or use case, every Product Passport should include at minimum:

  1. A product name that actually describes the product. "Men's Running Shoe – Meridian Trail 4 (Low) MT4-2291", not just "MT4-2291".
  2. An HS10 code provided or validated by the importer.
  3. At least one importer-validated sub-tier supplier beyond tier one, with each party's role in the production process and their location clearly delineated.

Passports that meet only the baseline are still useful. The expectations of customs agents may change when a known risk exists in a supply chain that the importer is trying to mitigate ahead of arrival.

Best Practices for Mitigating Known Forced Labor Risk in an Apparel Value Chain

The passport and supporting documentation — packing lists, bills of lading, certificates of origin, and attestations — should identify each stage of production:

  1. Raw cotton grower / baler
  2. Cotton ginner
  3. Raw cotton spinner / yarn dyer
  4. Fabric producer (knitter / weaver)
  5. Garment cutter / sewer / assembler / finisher

Include a note explaining why and how the passport mitigates the risk. Documents alone do not do the work — the narrative connecting them does.

Example. "As noted in the attached Certificate of Origin, Northfield Fibers shipped yarn from Vietnam to Halcyon Textile Group in Ningbo, China. There was no exposure to Halcyon's affiliate in Xinjiang. Knitting was performed by Northfield Fibers Vietnam at the address listed in attached affidavit 121a-10, and the cotton was sourced from the United States and Australia (origin supported by attached Packing Lists 1a and 1b and Certificates of Origin 1c and 1d)."

Pay particular attention to input weights. Verify that all sources of input are reflected in the passport and that the quantities are internally consistent — 1 kg of cotton cannot produce 100 kg of cotton shirts, and reviewers check for exactly this kind of gap.

Include a Certificate of Origin for the finished product.

Best Practices for Mitigating Other Risks

  • Passport and supporting documentation — packing lists, bills of lading, certificates of origin, and attestations — identifying the multi-stage production process from constituent raw material inputs through to the finished product.
  • The major production steps and inputs, reflected in the passport itself.
  • A note explaining why and how the passport mitigates the risk.
  • A Certificate of Origin for the finished product.

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