By Gary Symons
Editor-in-Chief
A report from the supply chain compliance consultancy TrusTrace has found that more than one in five fashion brands have had shipments detained in the United States.
Data in the report, “The Enforcement Era: Fashion’s Compliance Readiness in Numbers,” have significant ramifications for the entire fashion industry.
It revealed that a lack of supply chain traceability is impacting fashion brands around the world because licensee manufacturers often lack supply chain traceability.
In the most eyebrow-raising finding, TrusTrace found that more than one in five fashion brands reported that some of their shipments to the U.S. have been detained. Additionally, 75% of brands were not fully ready to provide the origins of materials used in their products on demand.
The report is being unveiled as part of the Textile Exchange Conference in Vancouver. The theme of this year’s event is “The Implementation Era,” which puts the focus on turning compliance commitments into action.
TrusTrace compiled the data in this report by surveying 57 sustainability, compliance, and supply chain leaders in 24 countries to examine brands’ current compliance practices and preparedness.
The timing of the report is important in another way because new regulations and increased enforcement are heaping more costs and delays on companies that don’t have complete traceability data for the products they are importing from their licensee partners.
“Supply chain traceability used to be a sustainability initiative. In 2026, it is a trading condition,” TrusTrace said. “With the EUDR and PPWR coming into effect this year, the EU Forced Labor Regulation following in 2027, and Digital Product Passport (DPP) requirements on the way, the report finds that the gap between regulatory awareness and operational readiness is already having commercial consequences.”
The key finding is that, due to increased scrutiny and enforcement, 21% of brands selling into the U.S. have had a shipment detained by U.S. Customs and Border Protection (CBP). Of those that have not, more than half (58%) consider it a realistic near-term risk.
Visibility drops sharply below Tier 1, the company notes in its report. While 75% of brands hold trusted data on their Tier 1 factories, that number falls to 33% at Tier 3 (yarn and fiber) and just 20% at Tier 4 (raw material and farm level), which is also the layer where enforcement agencies look for proof of origin.
The Digital Product Passport is a regulatory requirement for textile products in the EU that provides detailed information about a product’s lifecycle, including its composition and environmental impact. TrusTrace found that complying with the DPP is a high priority, but confidence in the underlying data remains low.
More than two-thirds (69%) of brands are actively preparing for the DPP, yet the same group rates its supply chain data accuracy at a median of just 3 out of 5.
TrusTrace also says basic due diligence is falling behind in the face of increasingly stringent regulatory requirements.
Only 21% of brands run continuous, automated compliance across their suppliers, 17% still rely on spreadsheets and email, and nearly half (48%) of U.S.-selling respondents have not yet screened suppliers against U.S. government forced labor entity lists.
The report was written by sustainable fashion journalist Megan Doyle and edited by Pauline God, who is the industry and policy expert at TrusTrace. The full report features in-depth interviews with TrusTrace customer Brooks Running and U.S. apparel group Komar, alongside perspectives from Christian Hudson of the UN Centre for Trade Facilitation (UNECE), and Julie Robertson of PIP Global Safety.
“Enforcement is no longer on the horizon. It is here,” the report states. “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.”
TrusTrace says that while compliance can be onerous, companies that invest in traceability perform better than those that don’t because they don’t incur the costs involved when shipments are tied up at a border post.
Investing in compliance is now a competitive advantage, TrusTrace argues.
“The brands pulling ahead built compliance into how they operate,” said Shameek Ghosh, CEO and co-founder of TrusTrace. “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, is among the experts interviewed for this report. He says there is an understandable frustration with the many different regulatory regimes that exist, but adds that straightforward tracking of traceability data is the best way to deal with compliance in general.
“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,” Mohamed said. “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.”
So, what is the best way to ensure your products get through the final hurdle in the supply chain?
TrusTrace provides a five-stage “readiness framework” in its full report, which was created using data and strategies from the brands that are consistently meeting or exceeding the reporting requirements.
Those five stages include “Know your supply chain, extend visibility to raw material, connect data across functions, automate compliance monitoring, and build documentation readiness.”
The report also sets out a 90-day compliance agenda, “including an honest baseline of tier visibility, entity list screening, and a documentation stress test modelled on a CBP (Customs and Border Protection) inquiry.”
TrusTrace is a global leader in supply chain traceability and compliance, helping brands turn supply chain data into decisions at scale. TrusTrace is trusted by many of the world’s largest and most ambitious brands and has been recognized by the World Economic Forum as a Top Innovator supporting the UN Sustainable Development Goals. The company is headquartered in Stockholm, Sweden, with offices in India and the U.S.
You can download the report for free at THIS LINK.
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