A new report from TrusTrace finds that 21% of fashion brands exporting to the US have faced shipment detentions, signaling enforcement risks are now a reality rather than a distant threat. The study, based on responses from 57 supply chain leaders across 24 countries, reveals a growing gap between brand awareness of stricter trade rules and their ability to prove material origins when challenged by US border authorities.
Visibility drops sharply at lower supply chain tiers
The report highlights how brand oversight weakens as supply chains deepen. While 75% of respondents said they track trusted data at Tier 1 factories—the final assembly stage—only 33% have visibility into Tier 3 suppliers, covering yarn and fiber production, and just 20% at Tier 4, where raw materials and farm-level sourcing occur. This matters because customs officials increasingly demand evidence from these earlier stages for origin verification and forced labor investigations.
Nearly three-quarters of brands (75%) admit they cannot immediately prove material origins if required, leaving them vulnerable to delays. Among brands that haven’t yet faced detentions, 58% still consider it a near-term risk, suggesting the problem is spreading beyond early adopters.
The lack of standardized documentation requirements adds to the challenge. Mills, processors, and raw material suppliers often receive conflicting demands from brands and regulators, creating uncertainty about what constitutes sufficient proof. Tahagod Mohamed, a traceability analyst at Brooks Running, called this inconsistency a major obstacle. “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. 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,” said Tahagod Mohamed, a traceability analyst at Brooks Running.
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Automation and data gaps slow compliance efforts
Basic compliance processes remain uneven. Only 21% of brands run continuous, automated checks across suppliers, while 17% still rely on spreadsheets and email. Nearly half (48%) of US-bound brands have not screened suppliers against government forced labor entity lists, a basic but critical step under new regulations.
Preparation for the EU’s Digital Product Passport, a requirement for tracking materials and environmental impact, reveals further weaknesses. While 69% of brands are actively preparing, the same group rated their supply chain data accuracy at just three out of five. Supplier resistance or limited capability was cited as the top obstacle (60%), though 63% said industry-wide data standards would accelerate progress more than any other factor.
Regulatory shift turns traceability into a trade requirement
Stricter rules on deforestation, packaging waste, forced labor, and digital product information are forcing brands to treat traceability as a trade necessity, not just a sustainability effort. The report notes that visibility often fades after garment assembly, leaving gaps in tracking fibers, yarns, and raw inputs across global supply chains.
