Suppliers & quality

Unauthorised factory subcontracting: what to do

Pause new purchase approvals and request a hold on affected goods. Establish where production happened, trace the batches, commission independent checks and reassess the compliance evidence before agreeing written restart conditions. Cambridge China Bridge can coordinate these checks through its staff in China.

Written by Bono Xu, Founder, Cambridge China Bridge · 4 min read · Updated 2026-10-25

A worker in a hi-vis vest and hard hat inspecting machinery in a plant

Identify the actual site and affected batches

Ask the contracted supplier for the subcontractor’s business name, production address, contact and work performed. Establish whether it handled components, assembly, finishing, packing or the complete product. Request production records, material issues, transfer notes and dated photographs. Visit the actual production site; an inspection at the contracted supplier’s showroom cannot establish what happened elsewhere.

Build an affected-batch register linking orders, product variants, production dates, materials, cartons, shipments and customer deliveries. Mark each connection as confirmed or unresolved. Where records cannot separate subcontracted goods from other stock, widen the temporary hold until evidence supports a narrower boundary. Use supplier batch traceability for the underlying records.

Request containment and preserve evidence

Send a written containment request identifying the goods and activities to hold: further production, transfers, packing and shipment. Ask for acknowledgement, stock locations, quantities and a named owner. Request segregation and clear hold labels at every relevant site. Ask your forwarder and warehouse what can still be stopped, and obtain confirmation of what has actually been held.

Preserve correspondence, original records, retained samples and photographs before rework or disposal changes the evidence. Assess goods already delivered separately. UK businesses must notify the relevant authority about products posing health and safety risks or found to be noncompliant. Follow the imported-product recall guide if the investigation raises a safety concern; do not wait for the supplier’s commercial explanation.

Commission checks independent of the supplier

Brief an inspector who is independent of the supplier to visit the actual site and reconcile production, transfer and stock records. Specify which processes, materials, equipment and finished goods to examine. Give the inspector access to your approved specification and reference samples, and ask them to record missing access or evidence rather than accept verbal assurances.

Have the inspector select samples from identified affected stock and record their batch, location and handling through delivery to the laboratory. Ask a suitably qualified laboratory or product specialist to propose checks based on the suspected changes and product risks. Keep site verification, workmanship inspection and laboratory testing as distinct findings; a satisfactory visual inspection cannot answer every material or safety question.

Reassess the evidence for the goods actually made

Compare the affected goods with the tested sample and approved specification: materials, components, construction, process, labels and instructions. Ask the report issuer to confirm which product and sample the existing report covers. Follow checking whether a test report covers your order rather than treating a familiar model name as proof.

Ask your compliance specialist whether the findings call for further testing, revised documentation or involvement from the organisation that issued certification. Record their reasoning for the intended market and product. Do not release affected stock while the connection between the goods and their supporting evidence remains unresolved.

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Set written conditions for resuming purchases

Require an explanation of how the subcontracting happened, corrective actions with named owners, verified closure evidence and an agreed list of production sites and permitted work. Make future site or process changes subject to written approval. Use controlling factory subcontracting for ongoing controls, while keeping this incident’s evidence and decisions together.

Separate approval to resume purchases from release of existing batches. Record the exact site, products and batches each decision covers, the evidence reviewed, unresolved restrictions and the authorised approver. Resume only within that documented scope. If access, traceability or corrective action remains inadequate, keep purchases paused and assess an alternative supplier.

Frequently asked questions

My factory subcontracted without permission. What should I do first?

Pause new purchase approvals, request containment and preserve the evidence. Identify the actual production site and map affected batches before accepting rework or shipment.

Do I need to reject every subcontracted batch?

Decide batch by batch using traceability, independent findings and the relevant compliance assessment. If records cannot distinguish affected goods, keep a wider hold until the boundary is supported.

Can I use the original factory’s test report?

Ask the issuer whether it covers the goods actually produced. Compare materials, components, construction and processes. Record the specialist’s assessment of any further testing or documentation needed.

When can I order from the factory again?

After the agreed restart conditions have been verified and an authorised buyer has recorded approval for the specified site and products. Approve release of held batches separately.

Sources

  1. Business notifications of unsafe and noncompliant products

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