# Methodology

## Scope and question

This project asks what publicly available records and reporting show about cotton, textile, garment-making, ownership, and buyer links between Esquel-related entities in China, three Vietnamese garment makers, and U.S. retail. It does not determine the cotton origin of any finished garment or make a forced-labor allegation about a product.

## Research steps

1. **Set the legal baseline from primary sources.** Review the Department of Homeland Security's UFLPA announcement dated Oct. 31, 2024 and its current entity-list page. Record the companies named, effective date, the listed aliases, DHS's stated basis, and the distinction DHS made when Changji Esquel moved between UFLPA sections. Review the Federal Register Commerce rule (FR Doc. 2020-15827) for the separate BIS Entity List action affecting Changji Esquel. Review Treasury/OFAC's July 31, 2020 XPCC action.
2. **Check the named company's response.** Include Esquel's public 2020 denial concerning Changji Esquel, without treating the denial as independent proof or omitting it from the presentation.
3. **Review reported corporate and trade links.** Use Reuters' Sept. 25, 2026 reporting, also available through the linked Devdiscourse syndication. Record the three maker names, former branding/rebranding timeline, reported common offshore ownership, Esquel cotton-export statistics, U.S. garment exports, buyers, and company responses as claims attributed to Reuters.
4. **Represent evidence at the narrowest supported level.** When the reporting only identifies a group of three factories or says a buyer sourced from one or two of them, draw a group-level edge. Do not invent an individual factory-to-buyer pairing. Keep XPCC as separate regulatory context rather than drawing an unsupported cotton-supply edge.
5. **Attach traceable citations.** Every entity and relationship object carries one or more source URLs and the date the source was accessed. The visible panel distinguishes role, geography, listing status, evidence text, and confidence.
6. **Mark unanswered questions before enriching the data.** The next research pass is reserved for the user's ImportYeti shipment records, Vietnam registry results, and OpenSanctions screening. Until supplied, this scaffold does not claim those findings or assume a match/no-match outcome.

## Confidence labels

- **Confirmed by government record:** a government record confirms the specific fact described, such as an entity-listing date, the text of a listing, or an agency's stated finding. It does not mean that all underlying allegations have been independently adjudicated, or that every downstream product has a particular origin.
- **Reported by press:** a claim attributed to Reuters' reporting. It is not silently upgraded to a government-confirmed fact.
- **Unverified:** evidence is incomplete, unresolved, or awaiting primary-document confirmation. This scaffold uses careful placeholders for information not yet provided.

The label describes the source basis for the statement. It is not a numerical probability or an endorsement of the source.

## What is confirmed, reported, and inferred

### Confirmed in government records

- DHS announced the addition of Esquel Group, Guangdong Esquel Textile, and Turpan Esquel Textile to the UFLPA Entity List effective Nov. 1, 2024. DHS also described the continuing UFLPA presumption for goods produced by Changji Esquel after a section change.
- The 2020 BIS rule added Changji Esquel to the Commerce Entity List, and Esquel published a denial of forced labor at the mill.
- DHS's current UFLPA list includes XPCC; Treasury announced the XPCC SDN designation on July 31, 2020.
- DHS described Esquel Group as sourcing cotton from Xinjiang and Turpan Esquel as producing and selling cotton and cotton yarn there. These official statements are not item-level tracing evidence.

### Reported by Reuters

- Three Vietnam makers—An Loi Apparel, Tessellation Binh Duong, and Tessellation Hoa Binh—used variations of Esquel Garment Manufacturing Vietnam before rebranding in October 2022.
- Reuters reported that three offshore firms owned the makers before and after the name changes. The names and underlying registry documents have not yet been entered in this scaffold.
- Reuters reported Esquel Group spun off consumer brands and technology operations into Tessellation Group in 2022, but could not determine whether Tessellation Group ultimately owns the Vietnamese makers.
- Reuters cited customs data for Esquel cotton exports to the three makers and cotton goods exported from Vietnam to the United States. The Vietnamese makers also sourced from other entities.
- Reuters reported buyer relationships and published responses from Muji and Rodd & Gunn. Muji and Rodd & Gunn said they were unaware of any Esquel link; their other stated actions and sourcing policies appear in the narrative.
- Reuters said it could not establish whether U.S.-bound products contained cotton produced by Esquel Group or in Xinjiang. This limitation is prominent in the page and must not be weakened in future edits.

### Inferred or not established

- No edge in the map represents product-level cotton tracing. Reported company-level export flows do not establish the origin of fibers in particular goods.
- The map does not identify the exact maker-to-buyer pairings when the reporting only names a set of suppliers.
- The group-to-Tessellation line describes a reported operational spin-off, not current ultimate ownership.
- XPCC's presence in a sanctions list does not establish that it supplied cotton to any other mapped entity.

## Free-tool workflow for extending the research

1. Search the official DHS list and Federal Register/GovInfo records for exact entity names and aliases. Save the source page, relevant dates, and a short claim-level note; distinguish the UFLPA list, Commerce BIS Entity List, and OFAC SDN list.
2. Use ImportYeti's public search interface to search each Vietnamese maker's exact and former names. Record the consignee, shipper, shipment count, date range, and HS code only as ImportYeti displays them. Preserve a URL or stable search reference and access date. Treat database coverage as partial, and avoid interpreting a bill-of-lading description as a verified bill of materials.
3. Search Vietnam's official business-registration resources for the exact legal entity names, registration numbers, name changes, and ownership filings. Capture the document date and field/page that supports each claim. Where no primary filing can be located, record “not found in the sources checked,” not “does not exist.”
4. Screen exact names and aliases in OpenSanctions. Record the query term, result URL, access date, matched identifiers, and whether the result was manually reviewed. A name-only similarity is not a confirmed identity match; no result is not proof of absence.
5. Add each substantiated company as an entity and each sourced connection as a separate relationship. Include URLs and access dates on every item. Keep unmatched, conflicting, and missing data explicitly unresolved.
6. Before publication, check that every public-facing factual statement links to a source, that company responses and denials remain represented, and that no wording implies any product contains forced-labor cotton absent direct evidence.

## Limitations

- The project begins with one official-record set and one Reuters investigation; it is not a comprehensive trade, ownership, or compliance investigation.
- Public customs and shipment databases may be incomplete, delayed, indexed under variant spellings, or omit meaningful product and buyer details.
- Company registry access and disclosure quality vary by jurisdiction. A shareholder, representative, officer, or nominee is not necessarily a beneficial owner.
- Similar company names and aliases create false-positive risks in sanctions screening. A reliable identity match needs identifiers and cross-source corroboration.
- Entity-list status and OFAC designation are legally distinct. This page records the type of action rather than describing every listing generically as a “sanction.”
- Trade-flow evidence, cotton sourcing statements, and common industry blending practices cannot confirm fiber content in an individual shipment.

## Ethics and correction practice

Use only relevant public corporate information. Do not add private personal details. Attribute allegations and unverified claims. Preserve company denials and buyer responses alongside claims. Correct errors by updating both the source-linked data and this methodology, and note the correction in the project history when published. This map is not legal advice and should not be used to assert wrongdoing or product composition unsupported by the sources.