Ask Who Actually Makes Your Order: A Subcontracting Disclosure Request

Yes. Ask whether any part of your order will be produced, finished, inspected or packed somewhere other than the facility you were shown, and ask it in writing before the order is placed. The point is not that subcontracting is rare or improper; it is common and often sensible. The point is that once work moves, the people who set the tolerances, keep the records and decide whether a defect is acceptable may not be the people you have been talking to. A spoken assurance is difficult to rely on months later. A written disclosure is a record.

This article is commercial sourcing guidance, not legal, customs or regulatory advice.

What actually changes when the work moves

Your commercial relationship stays with the seller of record, and so does your daily contact. What moves is the chain behind them. Consider what sits behind a single purchase order:

• The process may run on equipment you never saw, set up by someone who never read your specification in full.
• The inspection criteria may be written by the seller but applied by a different team, or applied loosely because the criteria were never translated into the language used on that floor.
• The records may be held in a different place, in a different form, or not at all.
• A rework decision may be made by someone whose incentive is to ship, and rework is easy to hide when it happens off-site.
• Final packing and labelling may happen at a third site, and that is where mix-ups between variants tend to occur.

None of this means the goods will be bad. It means the number of places where a defect can be introduced, missed or quietly corrected is larger than the number of places you can see. The disclosure request exists to make that list visible while you can still act on it.

Why the yes-or-no question fails

"Do you subcontract production?" is easy to answer defensively, because it sounds like an accusation. A supplier with nothing to hide may still answer vaguely, because the honest answer is often "sometimes, depending on the operation and the season" — which is true but useless to you.

The question that produces usable information is narrower. For each operation on your order: where does it run, who runs it, who inspects it, who keeps the records, and who is answerable when the result is disputed. That is the disclosure request.

Define your critical work before you ask

A supplier cannot disclose what you have not defined. Before sending anything, make your own list of the operations that matter for your product, and decide why each one matters. Our editorial suggestion is to treat an operation as critical if any of the following is true:

• A defect in it cannot be seen at goods-in; it surfaces later, in assembly, in transit, or at your customer.
• It determines fit, strength, finish or another attribute your customer or market asks you to demonstrate.
• It depends on specialised or calibrated equipment, so a substitution is not equivalent.
• It can be reworked, which makes problems easy to correct rather than report.
• It is the last step before the carton is sealed, where labelling and quantity errors become your problem.

If you cannot name the failure mode an operation could create, it probably does not belong on the list. A short list gets a better answer than a long one.

The disclosure request

Send it as an email or attach it to the request for quotation, while the order is still open to negotiation. Keep it as a set of blanks rather than a demand; the tone matters, because you are asking for a commitment you may later need to quote back.

Order and scope

• Item or product reference, and the specification revision the answer applies to
• Seller of record, and the facility you were shown or told about
• Date of the answer, and the name and role of the person answering

Where the work runs

• Operations the seller will perform at its own facility
• Operations the seller expects to place elsewhere, and the reason for each
• For each placed operation: the named facility, its location, and what that facility does
• Whether any placed operation may be moved again during this order, and who decides

Who owns quality

• Who writes the inspection criteria for each operation, and who applies them
• Who keeps the process and inspection records, in what form, in what language, and for how long
• Whether you or an inspector you appoint may attend at that facility, and on what notice
• Who accepts or rejects the finished goods, and who bears the cost of rework or replacement

Change and notification

• What counts as a change: new facility, changed process, changed material source
• When you are told, and by whom
• Whether you can decline a proposed change, and what happens if you do

Closing line

• A statement that the answers apply to this order rather than to the factory in general, with a space for signature, name and date

A plain phrasing helps. Something like: "Please confirm, for the order referenced above, which operations will be performed at your own facility and which will be performed elsewhere; for each, please name the facility and confirm who sets the inspection criteria, who keeps the records, and who is answerable for acceptance." That is a suggestion about wording, not a required form.

How to read the answer

A useful answer names operations and facilities, states who owns inspection and acceptance, and accepts some duty to tell you when things change. It may not be neatly formatted, and it may arrive as a paragraph in an email rather than a filled form. That is fine; what matters is whether the specific blanks are covered.

Treat these as unanswered rather than as reassurance:

• "We only work with long-standing partners."
• "It depends on capacity at the time."
• "All our partners follow the same standards."
• Any answer that covers who makes the goods but not who keeps the records or who accepts them.

The capacity answer deserves a second question rather than a challenge. It is often an honest description of how the factory plans. What you need from it is the decision rule: who decides that an operation moves, when you are told, and whether you can say no. A supplier who cannot describe that rule has told you something useful about how a change would reach you.

If a facility name is withheld, ask why in specific terms — confidentiality is a common and sometimes legitimate reason, and it can be handled by naming the facility to a third party under an undertaking instead of to you. What you should not accept is a refusal that leaves both the name and the quality ownership unknown.

Where public research helps, and where it stops

The Perform Due Diligence guidance from the U.S. International Trade Administration brings together country and company or partner risk research and points to official screening and commercial-guide resources. That kind of research can inform how you read a name once the disclosure form gives you one, and it is worth doing before you commit to an unfamiliar facility.

It does not certify anyone. A screening result is not a certification, and neither is a document that carries a certificate number or an audit report; each is something you read, not a conclusion you adopt. Treat any quality-system claim the same way, and note that a stated standard does not tell you which edition applies or whether it covers the operation you care about. Incoterms are also irrelevant to this exercise: they describe delivery responsibilities and do not prove quality outcomes or payment terms.

Turn the answers into something that survives the order

File the completed request with the purchase order and with the specification revision it refers to. When the order quantity, material or packing changes, re-send the same request for the changed scope rather than assuming the earlier answer still holds. If an operation does move mid-order, ask for the new facility name and record owner in writing at the time, not at final inspection.

Next action

Fill in the critical-work list for the order you are quoting now, convert it into the disclosure request above, and send it with the quotation request rather than after the order is confirmed. If you would like a second read before it goes out, send Sourcing Desk (supplier.ltd) your completed worksheet and the supplier's reply when it arrives; a brief can be reviewed, but any named facility, supplier claim, quotation, human follow-up or next step needs case-specific confirmation before you rely on it.