Michael

UFLPA & Amazon FBA: The 2025 Playbook for Zero-Detention Logistics A 7-Layer Defense Model for Sellers Targeting 0% Detention Rate WinsBS Fulfillment Research Team – Michael November 2025 Executive Summary TL;DR The 2025 enforcement cycle eliminated the Substantial Transformation loophole and shifted Amazon FBA detention risk from apparel to metals and lithium compounds. Vietnam and Thailand are no longer “safe” alternatives; CBP now follows the origin of the raw input, not the country of assembly. This playbook outlines the 7-layer Zero-Detention Framework used by multiple 8-figure Amazon brands maintaining less than 0.5% detention rate in 2025. Since early 2025, CBP and DHS/FLETF have intensified UFLPA enforcement across all FBA-bound supply chains. Over 16,700 shipments have been detained since mid-2022, totaling an estimated 3.7 billion dollars in restricted goods. A record 78 new entities were added to the UFLPA Entity List in the past 18 months, including a large-scale update in January 2025 affecting upstream metals and battery materials. For many sellers, the legacy strategy of shifting final assembly to Vietnam, Thailand, or Malaysia no longer mitigates risk. CBP now evaluates the “economic nationality” of a product based on its mineral or chemical origin — steel billet, copper cathode, lithium hydroxide, aluminum ingot, PVC resin — regardless of where the finishing assembly occurred. The combined tightening of UFLPA audits, Entity List expansion, and risk profiling of transshipment routes has created a new operational baseline for Amazon FBA importers. Traceability must now be batch-level, supplier declarations must be transaction-specific, and freight forwarders must maintain verifiable detention statistics to avoid unnecessary holds during Q4 and Q1 peak seasons. This report provides a structured 7-layer framework to help Amazon sellers, direct-to-consumer brands, and global exporters maintain zero-detention logistics in 2025 and prepare for DHS/FLETF 2026 updates. 2025 Enforcement Reality: What Changed and Why Legacy Playbooks Died By early 2025, CBP fully closed the Substantial Transformation workaround. Sellers relying on “final assembly in Vietnam or Thailand” discovered it no longer protects inbound FBA shipments from UFLPA detention. Origin now follows the mine, not the factory floor — meaning any product containing upstream materials traced to restricted regions remains prohibited regardless of downstream assembly. Enforcement volume has surged across metals, battery materials, and industrial inputs. CBP and DHS/FLETF data show a rapid shift in the profile of detained commodities as upstream minerals became the dominant signal in risk scoring models. 2025 Enforcement Snapshot Over 16,700 shipments detained since June 2022 Total estimated value exceeding 3.7 billion dollars 144 entities on the UFLPA Entity List, including 78 added in the past 18 months A major update in January 2025 added 37 upstream mining and processing entities Top flagged origins in 2025: China (#1), Vietnam (#2), Malaysia (#3), Thailand (#4) Transshipment now increases — not decreases — risk scoring The acceleration of metals enforcement, especially in steel, copper, and lithium compounds, has caught many Amazon sellers unprepared. These products typically pass through multiple tiers of suppliers, most of whom cannot provide raw-material provenance without a structured documentation system. 2025 Risk Velocity: Where Detentions Are Actually Moving Sector 2023–2024 Share 2025 Risk Velocity Why It Matters Cotton & Apparel ~45% Baseline Zero-tolerance is permanent; predictable but still strictly enforced Steel (New Priority) Less than 1% Explosive Growth Shelving, cookware, tools, auto parts — large spike in upstream-material detentions Copper (New Priority) Less than 1% Explosive Growth Wiring harnesses, electronics, plumbing fixtures — materials traced to upstream cathodes Aluminum ~6% High Increase Frames, foils, cookware — new mining entities added to the list Lithium / Batteries ~4% Sharply Targeted Power banks, EV accessories, toys — increased upstream hydroxide tracing PVC & Plastics ~5% Rising Vinyl flooring, shower curtains, packaging — resin tracing required Polysilicon / Solar ~12% Moderate Decline Share shrinking as metals rise — but still heavily policed Red Dates / Agri Negligible Emerging Early-stage enforcement expansion into agriculture Takeaway: Apparel is now “routine enforcement,” while metals and lithium compounds have become the silent drivers of new detentions — primarily because most sellers lack Tier-2 and Tier-3 documentation for these inputs. The 2025 Zero-Detention Framework: The 7 Layers Used by 8-Figure Brands Across Amazon FBA and cross-border ecommerce, the brands consistently maintaining less than 0.5% detention rate in 2025 all follow the same seven-layer system. This framework operationalizes UFLPA compliance into repeatable, shipment-level processes rather than one-time supplier paperwork. 1. Supplier Governance — Contractual Lockdown Every Master Service Agreement and Purchase Order includes a mandatory UFLPA/ESG addendum. Tier-1 suppliers must disclose Tier-2 and Tier-3 sourcing for all high-priority inputs (steel, copper, lithium, PVC, aluminum). Annual CBP-format Supplier Declaration is required, but not accepted as sufficient for shipment clearance. 2. Transaction-Level Traceability — The New Minimum Standard Annual certificates are now rejected by CBP. Each shipment requires a batch-tied packet: Raw-material invoice with batch or lot number Exact origin province or administrative region Third-party due-diligence report addressing forced-labor indicators Batch-linked Certificate of Origin or sworn statement 3. Four-Way Perfect Alignment (Non-Negotiable) These four fields must match exactly across all documents: Physical product label Commercial invoice Packing list Amazon ASIN “Country of Origin” field Province-level detail is now expected (e.g., “Guangdong Province, China”). 4. Freight Forwarder as Insurance Only work with forwarders that publish detention rates by commodity. Less than 1% detention on your category is the benchmark. Forwarders must be able to document routing integrity for Q4 peak season. 5. Document Readiness — Never Pre-Submit to Tier-1 Seller Support Proactive Amazon cases trigger mis-flags in 2025 more than any other behavior. Correct procedure: Prepare one encrypted ZIP (20 MB or less) per shipment. Upload only when the official request is generated — within two hours. 6. Real-Time Early-Warning Stack Top performers use automated signals: Helium 10 and Jungle Scout Sellerboard or API-connected dashboards Slack or Telegram alerts for “Reserved – Compliance Review” events 7. Quarterly Independent Audits — The Actual Competitive Moat Performed by Verité, Elevate, UL Responsible Sourcing, or Arche Advisors. Top sellers audit their 10 most important suppliers every 90 days. Rebuttal success rate rises from 35%

2025 Amazon FBA IPI Policy Deep Dive How to Avoid the Aged Inventory Surcharge (AIS) and Maximize Your ROI A Complete Guide for Shopify & FBA Sellers WinsBS Fulfillment Research Team – Michael November 2025 Executive Summary TL;DR You’ve hit your funding goal, but hidden fees in FBA could cost you thousands in excess storage and AIS penalties. WINSBS has helped thousands of US sellers avoid overpaying, reducing fulfillment costs by up to 30%. Read this 5-minute guide to avoid FBA AIS traps and save your margin. You’re a Shopify seller or FBA user, and your business is thriving. The excitement is high, and your customers are waiting. Now comes the real challenge: fulfilling your orders without draining your profits due to hidden Amazon fees. The new 2025 FBA IPI policy means your inventory management is more critical than ever. Incorrectly timed shipments or underestimating your storage needs can cost you significant extra fees, especially with the Aged Inventory Surcharge (AIS). You could end up spending 30%–50% more than expected, draining your profits. Amazon FBA is a vital platform for U.S. sellers, but it comes with its own unique challenges. From inventory limitations to the Aged Inventory Surcharge (AIS), managing your stock effectively is the key to avoiding unnecessary costs. That’s where WINSBS comes in. We’ve successfully helped over 3，000+ U.S. sellers (2025 YTD) optimize their FBA operations, saving them an average of 25% on fulfillment costs. This guide will walk you through the critical FBA IPI updates, how to avoid AIS penalties, and how WINSBS can help protect your margins. Key Changes in 2025 FBA IPI & AIS Risks – What You Need to Know The landscape for U.S. sellers is shifting in 2025 as Amazon updates its Inventory Performance Index (IPI) policy and introduces stricter regulations for the Aged Inventory Surcharge (AIS). Understanding these changes is crucial for managing your fulfillment strategy and avoiding unnecessary costs. Here are the key updates you need to be aware of: IPI Update Frequency: In 2025, the IPI score is now updated weekly instead of quarterly, which means your inventory health will be evaluated more frequently. This change requires proactive management to avoid penalties and keep your score above the threshold. Capacity Limits: Starting in May 2025, storage limits will be reduced to 5 months of forecasted sales, down from the previous 6-month threshold. This is especially important during peak seasons like Q4 to avoid exceeding storage limits. Aged Inventory Surcharge (AIS): AIS penalties now begin at 181 days, and the surcharge gradually increases as inventory ages. Proper inventory management is key to avoiding these increasing fees. With these updates, it’s more important than ever to ensure you’re working with a specialized fulfillment partner who understands the intricacies of Amazon’s new policies and how to avoid costly mistakes that could impact your bottom line. Below is a quick summary of the most important changes: Change 2024 Policy 2025 (Nov Update) Impact on Shopify/FBA Sellers IPI Update Frequency Quarterly Evaluation Weekly Refresh + Monthly Reset Real-time inventory monitoring is critical. Sync your data with tools like Zapier to stay ahead of changes. Storage Limits 6 months’ forecasted sales 5 months’ forecast (Effective May 2025) Reduced storage limits mean you’ll need to check your inventory regularly and plan shipments more frequently to avoid penalties. Aged Inventory Surcharge (AIS) Starts at 271 days Starts at 181 days Early action is required to clear excess stock before it incurs AIS penalties. Plan removals or sell off slow-moving items. Understanding these updates is the first step in adjusting your strategy to minimize risks and costs. Proper inventory management and timely actions can help you avoid unnecessary penalties and ensure that you are operating within Amazon’s rules. 5-Minute Self-Check: Is Your FBA Inventory on the AIS Path? You don’t have to wait for Amazon to surprise you with hidden fees. Take control of your inventory now before it’s too late. By performing this quick self-check, you can assess if your stock is heading straight for the Aged Inventory Surcharge (AIS) trap. The new 2025 FBA policies make inventory management more important than ever. With real-time IPI monitoring and smart inventory tools, you can stay ahead of any penalties and protect your bottom line. In this section, we’ll help you quickly assess your inventory for potential issues that could trigger AIS fees. Here are the key questions to consider: Excess Inventory: Do more than 20% of your stock have a shelf life of over 90 days? If so, you’re at risk of incurring high AIS penalties. Stockouts/Accurate Listings: Have you experienced stockouts for more than 3 days in the last 30 days? Low inventory accuracy can lead to penalties or restrictions. Sales Velocity: Are your products moving quickly? Slow-moving items increase the risk of higher AIS fees. Now, let’s dive into your self-assessment. Check your inventory against the following criteria: Inventory Check What to Look For Risk Level Suggested Action Excess Inventory More than 20% of stock over 90 days High Immediately remove excess stock from FBA or run a flash sale to move items quickly. Stockouts More than 3 days of stockouts in the last 30 days Moderate Replenish stock right away and make sure your listings accurately reflect current inventory levels. Sales Velocity Low sales velocity (under 60% sell-through rate) Moderate Run promotional offers or bundle products to boost sales and reduce slow-moving inventory. If your inventory check reveals any red flags, it’s time to act fast. Clearing out excess stock early will save you from unnecessary AIS penalties and keep your fulfillment costs under control. Use tools like WinsBS to sync your Shopify data with Amazon FBA and ensure your inventory is always up-to-date. Quick Fixes for Shopify-FBA Sellers: Emergency, Seasonal, & Long-Term Solutions Now that you’ve assessed your inventory and identified potential risks, it’s time to take action. In this section, we’ll go over some quick fixes to help you reduce AIS fees and keep your fulfillment costs in check. 1. Emergency Response: IPI

Top 5 Hidden 3PL Costs: Why They Hurt U.S. E-commerce & How to Fix Them in 2025 WinsBS Fulfillment Research Team – Michael October 2025 Executive Summary Core Challenge: How a Single $1.50 Accessorial Fee Can Cost Your Business $180,000 Annually For high-volume US-based e-commerce brands, third-party logistics (3PL) is the critical infrastructure enabling the two-day shipping and free returns consumers demand. However, for many growing U.S. eCommerce brands, profit erosion doesn’t come from base fulfillment fees—it comes from hidden accessorial charges buried deep in the fine print. Industry Insight: Logistics audit analyses indicate 92% of operators report unforeseen surcharges on returns cause a quarterly profit margin decline of 5% to 12%. This scale effect is astonishing: a trivial $1.50 surcharge per order, at 10,000 orders/month, is an annual profit drain of $180,000. This guide audits the five most predatory 3PL cost traps, offering contract negotiation and continuous auditing strategies to reclaim control. Top 5 Hidden Cost Traps in 3PL TOP 1: Storage Overages & Penalties: The FBA-Style Inventory Trap Summary : Base storage fees are rarely the issue—it’s the penalty structure behind them that silently doubles your cost. Hidden Cost Type The Problem to Watch For Mitigation Strategy (Contract Negotiation Focus) Long-Term Storage Surcharges Rates can double or triple past the 30-to-60-day “free period,” often with no cap, punishing slow-moving inventory. Negotiate Tiered Rates and Caps: Mandate a hard maximum rate cap. Require proactive WMS alerts (e.g., 15 days notice) for inventory nearing the overage threshold. Minimum Volume Commitments (MVC) You are billed for unused pallet or cubic foot capacity if your inventory falls below the required minimum. Demand Flexibility and Buffer: Negotiate a floating buffer zone (e.g., ±20% fluctuation). If penalized, negotiate paying only the “Service Fee Differential,” not the full unused fee. “Common Area” Allocation Fees Some contracts allocate non-storage costs (aisles, offices) proportionally, inflating your billable space by 10%–15%. Demand Transparency: Stipulate that storage fees must be based only on the actual footprint of your product shelves/pallets, excluding shared facility overhead. TOP 2: Accessorial Charges: The Carrier Surcharge Markup Time Bomb Summary : What really costs you isn’t the shipping fee—it’s the invisible surcharges you can’t see or control. Hidden Cost Type Core Content Mitigation Strategy (Operational Control Focus) Residential Delivery Surcharge (RDS) Rising fee (approx. $4.00–$5.35/piece) applied to residential orders (60% of US volume). A common target for 3PL markups. Third-Party Carrier Audits: Use audit software to verify the 3PL is NOT adding an administrative fee on top of the official carrier RDS. Use USPS Priority Mail for small residential parcels for lower or no RDS. Fuel Surcharge Markup A percentage fee based on carrier rates. 3PLs often add their own admin markup on top of the floating cost. Set Markup Cap: Negotiate to follow the official carrier fuel surcharge rate; prohibit any 3PL administrative markup. Require monthly reports based on the official EIA index. Dimensional Weight (DIM) Discrepancies DIM weight is greater than actual weight. Oversized packaging by the 3PL rapidly escalates your freight cost. Mandatory Package Engineering & Penalties: Enforce maximum acceptable packaging dimensions in your SLA. Include a penalty clause allowing you to charge the freight cost differential if excessive packaging leads to a carrier rate upgrade. TOP 3: Fulfillment & Labor Fees: Unexpected Manpower Bills Summary : Be wary of tasks vaguely defined as “extra labor”—they are often breeding grounds for hidden fees. Hidden Cost Type The Problem to Watch For Mitigation Strategy (Process & Documentation Focus) Inbound Prep Fees Charged if your shipment lacks necessary barcodes (UPC, GS1) or has incorrect palletization. Standard Operating Procedure (SOP): Provide a detailed Inbound SOP. Negotiate an initial grace period (e.g., first 5 shipments free adjustment). Only accept charges for non-compliance documented with photo evidence. Kitting & Re-Packaging Assembling gift sets or bundles. Rates escalate dramatically if the scope is temporarily modified mid-contract. Pre-Negotiate Rates: Define all potential kitting projects (e.g., 3-piece assembly) and set clear per-piece rates before signing. Avoid using temporary hourly labor rates unless absolutely necessary. Returns Processing Fees Cost to inspect, re-stock, and re-package returned goods. This is usually the highest variable cost. Tiered Returns Policy: Divide returns into clear Tiers (Tier 1: quick check/restock; Tier 3: refurbishment/cleaning). Negotiate a lower rate for Tier 1 returns, and aim for a total cost cap on Tier 3 processing. TOP 4: Contractual Fine Print: The Crucial Landed Cost Liability Clause Summary : Liability waivers written for the 3PL can force you to pay twice when inventory is lost. Hidden Cost Type Core Content Mitigation Strategy (Legal Review Focus) Inventory Shrinkage Liability Compensation typically defaults to Cost Price, not replacement or Landed Cost, for lost/damaged inventory. Negotiate to Landed Cost (Critical): Consult legal counsel. Negotiate compensation to cover, at minimum, Landed Cost (Cost + Inbound Freight + Duties). Define a shrinkage tolerance (e.g., 0.5% of total inventory); losses over this threshold must be the full financial responsibility of the 3PL. Early Termination Penalties Exiting a contract early (often 3 years) can trigger a massive penalty of 6 to 12 months of average service fees. Insert “Non-Performance” Escape Clause: Define clear, measurable SLA KPIs (e.g., 99.8% accuracy). Negotiate a clause allowing penalty-free termination if the 3PL fails to meet these KPIs for three consecutive months. IT/WMS Integration Fees Cost to connect your ERP/OMS (Shopify, NetSuite) to the 3PL’s WMS. Push for Fixed-Fee Agreements: Avoid hourly IT consulting rates. Negotiate a one-time, fixed implementation cost to prevent fee escalation due to unforeseen technical issues. TOP 5: Administrative & Management Fees: The Death of a Thousand Cuts Summary : Don’t let small, monthly “handling fees” bleed your long-tail profits. Hidden Cost Type Core Content Mitigation Strategy (Audit & Agreement Focus) Invoice Processing Fees A fixed monthly fee ($50–$200) to send you a bill or report. Consolidate or Waive: Negotiate to have this fee waived or included in the Minimum Monthly Commitment. If charged, demand only one consolidated master invoice per month to avoid multiple processing fees. Billing Discrepancy Surcharges Some 3PLs charge for the time

2025 3PL First-Mile Freight Costs Guide: Breaking Down Sea vs Air Shipping Fees for US Cross-Border E-Commerce Quick 3-Step Guide to Your 2025 3PL First-Mile Freight Costs Quickly spot risks and savings. Tap cards to expand. ? Step 1 – Identify Your Risks Tap to expand for your risks↓ Small <500kg/month: THC fees, de minimis duties apply. Mid 800–1500kg: LCL surcharges, FCL volume limits. Large >1500kg: Detention, inventory imbalance. ? Step 2 – Calculate Landed Cost Tap to expand formula & example ↓ = (Weight_KG * Rate_per_KG) + (Value * (Tariff_Base + 10%)/100) + (CBM * THC_35) + … Example: 400kg / 10 CBM electronics, $2,000 → Sea: ~$1,373, Air: ~$2,050 → Save $677 (25%) Paste formula into Excel or Google Sheets Enter weight, CBM, value, HS code (usitc.gov/hts → electronics → HS85xx) Add buffer days for potential delays ? Step 3 – Choose the Right Strategy Tap to expand strategies ↓ Small: Air + small-package; maintain 15-day buffer stock. Avoid LCL minimum thresholds. Mid: Shared FCL 10–15% savings, lock quarterly space, use LCL + dedicated line for misc fee reduction. Large: 80% sea + 20% air, pre-plan stock, contract free detention days. Case: Mid-tier seller Mike saved $8K and reduced turnover from 42 → 28 days by switching strategy. For US e-commerce sellers, 2025 freight is a balancing act: You need to ship fast enough to keep Amazon customers happy… but air freight at $6/kg can crush your ROI. You want to save with sea… but LCL’s “1CBM minimum” can trap you into overstocking. De minimis is gone, HS codes are trickier, and demurrage fees hit $120/day—one mistake and your quarter’s profit could vanish. I wrote this articlefor sellers who’ve had enough of “guesswork freight”: Skip the 45-minute Google searches—our 10-second self-check tells you if duties, fees, or delays are your biggest risk. No more “close enough” math—our Landed Cost formula includes every hidden fee (THC, LCL ops, even Q4 detention). See exactly how Mike saved $8k in Q3 (he ships 400kg/month—just like you) with a simple air/sea mix. This isn’t theory. It’s the same solution we’ve used with 1,000+ US sellers to cut freight costs by 15–25%. Take control of your freight costs—use Winbs check to see exactly what needs attention. 2025 First-Mile Freight Trends: Up 4-7% Overall, But It’s All About the Splits 2025 US cross-border shipping fees are splitting wide: LCL sea runs $1.1–2.1/kg on transpacific routes (up 20–25% YoY), FCL 20ft containers cost $3,500–4,800/unit. Economy air holds $3.2–6/kg, spiking to $6–7/kg during Q4 peaks. Policy alert: De minimis suspension begins Aug 29 for parcels under $800 (duties 3–6% + 10% baseline). B2C commercial shipments remain HS-based (e.g., electronics 3.5–5.6%). Transit update: Red Sea detours add 2–5 days in Q4; port congestion may worsen delays. IATA forecasts +5% air demand but rates remain flat. Seller impact: Small-batch shippers face misc fee jumps of 20% (THC costs rise), bulk shippers risk inventory mismatches. Quick action: Run the 10-second check below to identify if duties, fees, or delays are your top risk. 10-Second Self-Check: Freight Costs & Risks Seller Type / Monthly Volume Core Costs & Challenges Risk Level Recommended Action Small-Batch Sellers (<500kg/month) De minimis duties apply on <$800 parcels (3–6%) THC fees may represent 15–25% of shipping Fast turnover increases handling risk High Check Landed Cost; prioritize fast/air shipments; maintain small buffer stock Mid-Volume Sellers (800–1500kg/month) LCL surcharges 10–20% on some routes FCL minimums may impact flexibility Seasonal peaks require careful space planning Medium Balance LCL/FCL shipments; plan quarterly bookings; monitor demurrage fees High-Volume Sellers (>1500kg/month) Detention fees $50–80/day Inventory imbalances possible if demand fluctuates Sea freight preferable for cost efficiency Low Leverage sea freight; pre-plan stock levels; optimize warehouse rotation Identify your scale → Review costs & risks → Apply recommended actions to reduce shipping expenses. Full Landed Cost Calc Formula: Freight Cost Calculator = (Weight_KG × Rate_per_KG) + (Value × (Tariff_Base + 10%) / 100) + (CBM × THC_35) + (Delay_Days × Demurrage_120) + (Value × 0.5% Insurance) + (LCL_Fee_65 / Ticket) LCL Fee ($/Ticket): LCL operation fee per ticket FCL Fee ($/Ticket): FCL operation fee per ticket LCL FCL Weight (KG): Enter shipment weight in kilograms Rate per KG ($): Enter rate per kilogram Value ($): Enter shipment value for duties and insurance Tariff Base (%): Enter HS-based tariff percentage CBM: Enter cubic meters for THC calculation Delay Days: Enter estimated delay days for demurrage Tickets: Enter number of tickets for fee split Calculate Total Cost: — Contact WINSBS for Detailed Quote Var Breakdown: Tariff_Base = HS rate (electronics 3.5-5.6%); THC = Port handling $35/CBM; Demurrage = $120/day; Insurance = 0.5% of value. Example: 400kg / 10CBM electronics, $2000 value, HS 3.5% +10%: Sea $1.6/kg → $1,373 (~$3.43/kg); Air $4.5/kg → $2,050 (~$5.13/kg) — Save $677 (25%). Seller-Tier Strategies: Now that you’ve crunched the numbers, let’s match you to a strategy that actually fits your workflow—no jargon, just solutions to your biggest headaches. Quick summary: <500kg/month: LCL minimums (1 CBM / ~353 lb) force overstock. Use air freight + small parcels to avoid minimums. 800–1500kg/month: Too large for costly LCL but too small for a full container — consolidated (shared) FCL splits the cost. >1500kg/month: Mix sea and air to avoid stockouts and overstock caused by one-size-fits-all shipping. Small-Batch (<500kg/month) — Fast-moving goods Recommended: Air + small parcels (typically $4–$6/kg, 7–10 day delivery). How to implement Pick a carrier: Use services like ShipBob or WINSBS. Sign up, enter weight and HS code, and get a quote. Many providers have no minimum under ~50kg (110 lb). Mix transport: ~70% air for urgent restocks and ~30% sea for backup inventory. Reorder trigger: Restock when stock drops below 15 days of average sales; automate with Excel or an inventory tool. Avoid LCL minimums: LCL providers often bill a full 1 CBM even for smaller shipments—air + small parcels avoids that “empty-space tax.” Mid-Volume (800–1500kg/month) — Large items Recommended: Shared FCL (consolidated shipping) or LCL plus a dedicated freight line. How to implement Consolidated FCL: Search