More than one in five fashion brands have seen shipments detained upon entering the United States by Customs and Border Protection, according to newly released data from TrusTrace.
This is evidence that a new “enforcement era” has begun, the supply chain traceability platform asserted in its latest report, which debuted at the Textile Exchange Conference in Vancouver, B.C. on Tuesday.
The research, made up of insights from 57 respondents across 24 countries, showed that just 20 percent of firms possess verified data about their supply chains going as far upstream as the material and farm level.
As such, not only have 21 percent experienced detentions, but 58 percent consider having goods stopped at a border to be a realistic risk in the near term. A surprising contingent—75 percent—said they don’t feel fully prepared to prove the origins of their materials on demand, even though border scrutiny has reached new heights amid trade disruptions and fluctuations in tariff policy.
With that truth as a backdrop, supply chain traceability has evolved from a sustainability imperative to an essential part of modern trade, the report said.
With the European Union Deforestation Regulation (EUDR) coming into effect this year, the EU’s Forced Labor Regulation coming into play in 2027 and Digital Product Passport (DPP) requirements also on the way, TrusTrace’s research highlighted an uncomfortable truth for fashion brands: The delta between regulatory awareness and operational preparedness is taking a commercial toll already.
While firms have no doubt been following the progress of international regulations and the formation of new standards for years now, supply chain visibility positively plunges beyond Tier 1. While 75 percent of those surveyed said they had trusted insights from their immediate suppliers and factories, that access and transparency fell sharply to 33 percent at the yarn and fiber level, otherwise known as Tier 3.
Far fewer still (20 percent) said they had actionable data from their Tier 4 raw material suppliers—the layer of the supply chain that enforcement agencies typically scrutinize most heavily for proof of origin.
DPP has become a high-priority area for companies, but there’s still low confidence, at this juncture, in the data being collected. While 69 percent of brands said they were actively preparing for DPP regulations, those same respondents rated their supply chain data accuracy at a median of three out of five.
According to TrusTrace, there’s evidence that even the most basic due diligence practices are lagging in the face of escalating standards and scrutiny. Only one-fifth of companies queried said they run continuous, automated compliance across their suppliers, while 17 percent are still relying on spreadsheets and email. Almost half (48 percent) of survey-takers based in the U.S. haven’t used the government’s forced labor entity lists to screen their supplier portfolios, which would seem a natural first step to avoiding an unwanted detention.
The report’s creators, sustainable fashion journalist Megan Doyle and editor Pauline God, industry and policy expert at TrusTrace, wrote that coordination stands to be the biggest accelerator for progress, while supplier resistance or limited capabilities are the top barriers for 60 percent of respondents. More than three-fifths (63 percent) said industry-wide supplier data standards were an accelerator.
“Enforcement is no longer on the horizon. It is here. Border officials look at evidence to decide which goods move and which goods they hold. The industry has made real progress at Tier 1. But regulators ask for evidence that sits much deeper in the supply chain,” said Shameek Ghosh, CEO and co-founder of TrusTrace. “The brands pulling ahead built compliance into how they operate. They did not treat it as a single project. Brands that start now can still meet every deadline.”
Tahagod Mohamed, senior traceability analyst at Brooks Running, who was interviewed for the report, said, “The hardest part is that there is no single right answer for what a complete document set looks like at each level of the supply chain, which makes it genuinely difficult for suppliers to know how much is enough.”
Asked how he would direct brands, he added, “Our guidance to them is simple: Provide as much as you can to show how the raw material was produced, processed, transported and paid for to make the final product.”
TrusTrace’s report ends with a roadmap, divided into five stages, that is designed to put brands on a path toward readiness. Developed from the experiences of brands that are furthest ahead in the pack when it comes to compliance, the framework advises that those that feel behind tackle the issue in stages: Know your supply chain, extend visibility to raw material, connect data across functions, automate compliance monitoring and build documentation readiness.
The document lays out a 90-day compliance agenda, which features a realistic baseline for tier visibility, entity list screening and a documentation stress test that was developed based on a real-life CBP inquiry.
