“Can you make this?” is not the first factory question. A brand needs to know who the legal counterparty is, where each operation will occur, whether required registrations are current, who employs and supervises workers, what may be subcontracted, how capacity was defined, which product and safety controls apply, and how problems can be reported and corrected.
The goal is not to interrogate a factory into giving perfect answers. It is to create a shared, versioned record that exposes unanswered questions before samples, materials, production, customer promises, and money depend on them.
This guide does not approve a factory or determine legal compliance. Factory management statements are one source of evidence, not the only one. Direct worker engagement, site-specific verification, authorized records, and qualified labor, safety, technical, customs, sourcing, finance, and legal review remain essential.
Who is the contracting entity?
Ask for the legal name, business form, registration, tax identifiers when legitimately required, physical and mailing addresses, ownership and control information appropriate to the risk and law, authorized signer, contacts, and banking-change procedure. Verify sensitive details through approved channels.
List every relevant location and its role: sales office, sample room, cutting, sewing, knitting, embroidery, printing, washing, dyeing, finishing, pressing, packing, warehouse, and subcontractor. A showroom or trading-company address is not proof of the production location.
For California garment work, the Labor Commissioner says entities engaged in garment manufacturing—including contractors and manufacturers—must register. Its garment page also explains that SB 62 addresses hourly pay and responsibility for parties contracting for garment operations. Confirm current registration and applicability directly with the agency and counsel; a screenshot or expired certificate is not verification.
What exactly does the factory do?
Ask which product categories, materials, constructions, machines, processes, finishing operations, and quality levels the facility routinely handles. Request representative evidence it is authorized to share. A sample can show one outcome, but not who made it, under which conditions, at what scale, or with what repeatability.
Map the proposed product from material receipt through cutting, assembly, finishing, inspection, packing, and dispatch. Identify operations the facility does not control. For each external operation, ask who selects the subcontractor, where it occurs, how it is approved, how workers are protected, how material and lots are traced, and how a change is disclosed before work moves.
Do not accept “we never subcontract” as a permanent control. Put the permitted scope and change-notice process into the reviewed agreement and verify it during the relationship.
How is capacity defined?
Ask for current queue, confirmed commitments, sample capacity, production line or cell assumptions, equipment constraints, specialist labor, material dependencies, minimums, changeover, maintenance, holiday calendars, approval gates, and contingency. Define whether lead time starts at inquiry, purchase order, deposit, material receipt, approved sample, artwork approval, or another event.
Request a range and its assumptions, not one precise number. A stated monthly capacity is not automatically available capacity for the brand’s construction, size range, quality plan, and date.
Use a controlled sample or pilot to observe communication, specification interpretation, material control, first-piece approval, defect handling, and recordkeeping. Do not turn a successful sample into an automatic authorization for a larger order.
Who employs the workers, and how are they protected?
Ask who recruits, employs, schedules, supervises, records time, pays, and disciplines workers at every location. Review wage, overtime, timekeeping, pay statements, breaks, age, home work, temporary labor, production pressure, grievance, non-retaliation, and remediation under applicable laws.
The U.S. Department of Labor’s garment toolkit provides federal compliance resources and notes that more protective state laws may apply. California’s garment rules create additional registration and wage-responsibility questions. Engage qualified specialists for the actual jurisdiction.
Worker voice cannot be replaced by a management questionnaire. Build a lawful, safe, confidential channel with trusted labor expertise. Explain purpose, consent, confidentiality limits, non-retaliation, escalation, and remedy. Do not collect worker personal data into an unsecured sourcing spreadsheet.
What is the workplace-safety system?
Ask for responsible personnel, hazard assessment, injury and illness prevention, training, machine guarding, electrical safety, fire and exits, ventilation, chemicals, ergonomics, heat, personal protective equipment, incident reporting, emergency response, corrective action, and current agency findings or citations that the facility is legally permitted to disclose.
Observe whether exits and aisles are usable, guards are present, chemicals are labeled and stored appropriately, workers understand procedures, and corrections are sustained. A clean tour path is not a safety audit. Use qualified local reviewers and do not create risk for workers through an unannounced or coercive process.
How are specifications, quality, and changes controlled?
Ask which version of the tech pack, bill of materials, pattern, graded nest, color standard, approved sample, trim standard, packaging instruction, and test plan controls production. Determine how revisions are issued, acknowledged, removed from use, and traced to lots.
Review incoming material control, spreading and cutting, first piece, in-process checks, measurement, construction, appearance, final inspection, needle or sharp control where relevant, nonconformance, rework, disposition, root cause, corrective action, and record retention.
Define who can approve a deviation. A factory should not silently substitute material, trim, thread, adhesive, process, finish, packaging, or production site because the original input is unavailable.
Who owns product-safety and labeling evidence?
Map the finished product, intended user, markets, applicable rules, component evidence, tests, certificates, labels, claims, material changes, periodic review, records, and responsible certifier. CPSC testing and certification guidance is product-specific; children’s products and general-use products have different requirements.
FTC apparel guidance summarizes federal fiber, origin, responsible-party identity, and care-label requirements for covered goods. Confirm the actual product. A factory applying a label does not necessarily become the party responsible for deciding its content, and buyer approval does not cure an inaccurate label.
Run a documented change process. CPSC’s material-change guidance explains that changes can affect the testing basis. Determine who identifies, reports, reviews, tests, and approves a change before affected units proceed.
Can the factory trace materials, lots, and origin?
Ask how material receipts, rolls, dye lots, trims, cut bundles, work in process, rework, finished units, cartons, and shipments are identified. Test a forward trace from material to finished units and a backward trace from finished unit to inputs and production events.
For imported goods, CBP’s forced-labor guidance emphasizes reasonable care and understanding where and how products are made. Review supply tiers, origin evidence, manufacturer identity, trade restrictions, and records with qualified customs and legal professionals. A country printed on an invoice or label is not a complete origin determination.
Use official current tools for sanctions and restricted-party review. A name match or no-match is not a legal conclusion; aliases, ownership, geography, goods, and transaction context matter.
What happens when something goes wrong?
Ask who receives a worker, quality, safety, delivery, privacy, or trade concern; who can stop work or shipment; how evidence is protected; how retaliation is prevented; how root cause and remedy are documented; and how the brand verifies correction.
Define exit conditions, remaining materials, patterns, tools, confidential files, work in process, finished goods, records, worker remediation, open claims, access removal, and lawful transition. Do not allow an exit dispute to become an improvised inventory or payment action.
Commercial terms should separately cover sample cost, unit and pack basis, currency, material commitments, minimums, deposits, payment events, delivery definition, inspection, changes, cancellation, confidentiality, intellectual property, insurance, dispute route, and governing law. Obtain actual quotes and contract review; this article supplies neither.
A reproducible fictional question audit
content/data/FM-171-new-factory-intake.json contains four invented factory packets. scripts/fm171-new-factory-audit.php requires identity and locations, ownership, operations, capacity, subcontracting, worker voice, safety, quality, product safety, traceability, commercial terms, correction, professional review, and ownership.
NF-01 and NF-03 route to factory-review; that is not approval. NF-02 is held because registration, subcontracting, worker, safety, traceability, correction, and legal fields are open. NF-04 is held because capability, capacity, quality, safety, terms, correction, review, and ownership evidence is incomplete.
The script tests packet completeness only. A complete fictional field cannot prove a real registration, safe workplace, lawful pay, capacity, quality, origin, certification, price, or relationship.
Sources and verification
- California DIR: Garment Work in California — official SB 62, registration, wage, responsibility, claim, and resource entry point.
- California DIR: Garment Registration Document Requirements — official identity, location, and registration-document context.
- U.S. Department of Labor: Garment Compliance Assistance Toolkit — official federal garment wage-and-hour compliance resources.
- CBP: Forced Labor Frequently Asked Questions — official importer reasonable-care and supply-chain documentation context.
- CPSC: Testing and Certification — official product-specific testing and certification entry point.
- CPSC: Material Change Testing — official material-change and testing-basis context.
- FTC: Clothing and Textiles — official fiber, origin, responsible-party, care, and claims guidance.
- OFAC: Sanctions List Service — official current sanctions-list access; qualified legal interpretation remains required.