Quick answer
How can an importer control undisclosed factory subcontracting?
Name the seller, production site, critical outside processes, change rules, inspection access, and pickup location before money or production moves. Then connect every update to the actual order and approved factory.
What factory subcontracting means in China sourcing
Subcontracting means that a supplier relies on another company or location for part or all of the order. A trading company may coordinate several factories. A manufacturer may send specialized work to an approved processor. A busy factory may also transfer production to an unapproved workshop without telling the buyer.
The buyer does not need every screw or carton made under one roof. The buyer does need to know which site controls the critical product characteristics, whether that site was evaluated for the order, and who remains accountable for quality, delivery, records, access, and correction.
- Component subcontracting: purchased parts, electronics, hardware, fabric, packaging, labels, or other inputs
- Special-process subcontracting: molding, heat treatment, welding, coating, plating, printing, sterilization, or laboratory testing
- Capacity subcontracting: assembly or packing shifted because the quoted factory lacks line space, workers, equipment, or time
- Full-order subcontracting: the seller manages the transaction while a different factory makes and packs the goods
When subcontracting is acceptable and when it becomes risky
Controlled subcontracting can be normal when the process is disclosed, the outside site is capable, specifications and traceability move with the work, incoming and outgoing checks are defined, and the buyer’s inspection and correction rights remain intact.
Risk rises when the supplier conceals the site, cannot explain who controls production, changes factories after sample approval, or uses a location that cannot reproduce the approved material, process, testing, or packing method. A lower-cost workshop can change the product even when the seller and purchase order remain the same.
- Acceptable: named outside process, clear owner, approved specification, receiving check, traceable batch, and available records
- Caution: the supplier discloses a site only after deposit or cannot show how work is transferred and checked
- High risk: finished goods appear at a different address, inspection access is blocked, or the pickup location changes without a credible explanation
- Stop-and-review: the new site changes regulated materials, product claims, certification assumptions, safety controls, or the ability to correct defects
Verify the production site before deposit
Separate supplier identity from factory capability. The company receiving payment may be a manufacturer, exporter, trading company, affiliate, or service company. Ask for the Chinese legal names and addresses of the seller and the site that will make the order, then test whether the claimed equipment, workers, product history, and capacity fit the quoted product and timeline.
A remote review can find inconsistencies, but important orders may require an onsite visit or factory audit. The depth should follow product risk, order value, novelty, regulatory exposure, tooling dependence, and the cost of discovering the wrong factory after production.
- Legal seller, invoice issuer, payment beneficiary, exporter, factory operator, and relationship between them
- Exact production, finishing, packing, storage, inspection, and pickup addresses
- Product-specific equipment, process flow, sample source, line capacity, worker skill, and quality checkpoints
- Named sub-suppliers for critical materials or processes and the controls applied when goods return
- Whether the buyer, inspector, or nominated representative can access the actual goods and site
Put subcontracting controls into the order before production
A verbal promise not to subcontract is difficult to use when the schedule slips. The purchase order, manufacturing agreement, quality plan, or inspection instruction should identify the approved production site, critical outside processes, notice requirements, change-approval route, inspection access, record retention, and responsibility for nonconforming work.
The control should fit the product. A buyer may accept an approved packaging printer but prohibit transfer of final assembly. Another order may allow alternate molding capacity only after first-article approval and material confirmation. The rule must name what can change, who approves it, and what evidence is required before the changed process supplies bulk goods.
- Approved factory and processor names, Chinese addresses, and process responsibilities
- No-change rule for product-critical materials, tooling, process parameters, assembly site, or test method without written approval
- Transfer package containing the current drawing, bill of materials, golden sample ID, tolerances, defect limits, labels, and packing files
- Inspection access at the actual site plus a correction and re-inspection plan if the change creates defects
- Commercial consequences and qualified legal review appropriate to the contract and governing law
Evidence that production is happening at the approved factory
Do not rely on one cropped photo or a sales contact’s location pin. Build a consistent evidence set across time: site exterior and work-area context, product-specific work in progress, material and batch identification, equipment, production counts, packing status, inspection address, and pickup details.
Evidence should answer both where and what. A genuine factory video does not prove that the buyer’s order is there. Product photos do not prove which site made them. Stronger evidence connects the current order, current date, identifiable production stage, and approved location without exposing unrelated buyer information.
- Dated wide-context photos or live walkthrough covering the work area, order, equipment, and production stage
- Material, work-order, batch, line, carton, and quantity records that agree with the purchase order
- Inspection booking and report showing the actual site, contact, goods presented, and quantities available
- Supplier explanation for any different uniforms, walls, machines, labels, company names, contacts, or addresses
- Pickup address and packing evidence consistent with the production and inspection history
What to do when the factory or production site changes
Treat a site change as a new risk decision, not only a supplier update. Ask what moved, why, when, how much quantity is affected, which materials and tooling moved, whether production already started, and what controls were repeated at the new location.
Do not authorize an automatic balance payment, inspection waiver, or pickup release merely because the original supplier remains involved. Decide whether to accept, conditionally approve, inspect more deeply, require corrective action, return work to the approved site, or stop based on verified status and the buyer’s contract, quality, schedule, compliance, and commercial exposure.
- Pause the next irreversible step while facts are collected, where the payment terms and agreement allow
- Verify the new operator, address, process capability, product status, materials, tooling, and inspection access
- Repeat sample, first-article, process, testing, or inspection controls when the moved step can change product conformity
- Document approved deviations, affected batches, added checks, recovery dates, and correction responsibility
- Use qualified legal or regulatory advice when rights, certification, product safety, customs, sanctions, or forced-labor obligations may be affected

