Chain of Custody in Construction: What You’re Missing from PreCon to Closeout

Tariffs have spiked. Audits are stricter. And now your ability to get reimbursed may come down to a missing photo or timestamp. Chain of custody isn’t just a compliance requirement; it’s a risk management tool. When documentation falls short, so do reimbursements, pay apps, and trust across the delivery team. The problem? Most project teams don’t think about it until it’s too late.

Let’s change that.

What Is Chain of Custody, Really?

It starts well before a single item hits the jobsite.

Chain of custody begins in preconstruction, where expectations around material tracking, documentation, and traceability are introduced. Setting those expectations early, especially with subs, is the foundation of an audit-ready project.

Step 1: Start in PreCon

This is where the tone gets set.

During subcontractor onboarding or early trade partner meetings, clearly outline:

• Which materials require chain of custody documentation

• What types of documents are needed (e.g., certificates of origin, heat stamp photos, mill test reports)

• How and when documentation must be submitted

• What naming conventions or formats are required

Pro tip: Include a submittal checklist or example documentation package in your kickoff. When trade partners know what’s expected from day one, your paper trail begins before anything is ordered.

Step 2: Verify as You Go

Chain of custody isn’t a one-time task. It’s a sequence of checkpoints:

• During submittal review: Confirm origin data and required identifiers

• At delivery: Document contents, condition, and any visible markings or batch IDs

• At install: Verify and record that the right materials were used in the right place, with traceable info

  
  

Reminder: Chain of custody depends on multiple checks, not just uploading a few file. You need to know what was ordered, when it was sourced, and how it compares to what was installed.

That includes tariff tracking too. Prices, classifications, and country-of-origin exposure can all change between procurement and delivery.

Where the Real Opportunity Lies

Start in preconstruction by reviewing the spec and identifying:

• Which materials require documentation (steel, aluminum, electrical gear, copper, etc.)

• What level of traceability is needed, based on owner or federal requirements

• What your subcontractors need to understand before procurement begins

How ABW Helps: Built-In Chain of Custody Support

That’s where ABW Consulting’s automated system comes in. We support compliance across the full project lifecycle:

•  Submittal reviews that flag missing Certificates of Origin, MTRs, and other compliance requirements

• Prompt-based documentation checks to identify gaps and auto-generate fill-in-the-blank forms

• Photo-driven heat stamp extraction with folder organization to streamline tracking

• Verified closeout packages that assemble themselves, no last-minute PDF scrambles

It’s not about collecting more documents. It’s about making sure the right ones exist, match the spec, and are usable when reimbursement is on the line.

Step 3: Close the Loop at Install

Your chain is only as strong as its last link.

If the material makes it to the jobsite but isn’t verified or documented during installation, you lose traceability.

Installation records should include:

• Final location (e.g., Area B Mechanical Room)

• Installer confirmation

• Reference numbers or batch IDs

• Photos of installed materials with visible markings (when applicable)

Why It Matters

When done right, chain of custody gives you:

• A defensible audit trail

• Confidence during reimbursement and closeout

• Fewer surprises when field conditions, sourcing, or compliance questions arise

When ignored? It becomes a scramble. And in today’s shifting landscape, that scramble is getting riskier by the day.

The Tariff Variable: Why Your Process Can’t Stay Static

Tariffs aren’t stable and your documentation process shouldn’t be either.

What you ordered last year and what you’re receiving today may not align on paper.

Here's what changed:

• In 2023, the average U.S. tariff on EU goods was 1.2%

• Today, EU goods face 15% tariffs, a 13-point swing

• Steel, aluminum, and copper from some countries are now hitting 50%, often double what they were a year ago

If your documentation doesn’t clearly show when the material was sourced and at what rate, you're losing ground fast.

Chain of custody becomes your record of truth a time-stamped, verifiable story of what was purchased, when, where it came from, and how it made it to install.

Need to Get This Right? Let’s Talk

Chain of custody doesn’t have to mean more spreadsheets and chaos.

At ABW Consulting, we help construction teams:

• Auto-scan submittals for country of origin and compliance gaps

• Extract and organize traceability data from photos and PDFs

• Track documentation at every handoff, order, delivery, and install

• Maintain audit-ready records without interrupting your team’s flow

Whether you’re starting from scratch or cleaning up a paper trail mid-project, we can help you build a system that’s scalable, flexible, and aligned to real-world workload.

If you’ve got questions, DM me anytime. My agents always pick up.