Supply chain traceability and compliance specialist TrusTrace has published “The Enforcement Era: Fashion’s Compliance Readiness in Numbers”, a study showing that one in five or 21% of the fashion brands it polled that sell into the US has had a shipment held by customs authorities.
Meanwhile, three-quarters or 75% admit they are not wholly prepared to demonstrate where their materials come from when asked.
Its findings draw on first-hand responses from 57 sustainability, compliance and supply chain executives based in 24 countries, and assess how brands currently manage compliance and how well equipped they are for what lies ahead.
Tracing a supply chain was once treated as a sustainability project; in 2026 it is a condition of doing business.
The EU Deforestation Regulation (EUDR) and the Packaging and Packaging Waste Regulation (PPWR) both take effect this year, the EU Forced Labour Regulation follows in 2027, and Digital Product Passport (DPP) rules are approaching.
The study concludes that the distance between knowing the rules and being operationally ready to meet them is already carrying a commercial cost.
Key Findings
21% of brands selling into the U.S. have had a shipment detained by U.S. Customs and Border Protection (CBP). While, more than half or 58% consider it a realistic near-term risk.
75% of brands hold trusted data on their Tier 1 factories, falling to 33% at Tier 3 (yarn and fiber) and just 20% at Tier 4 (raw material and farm level). Tier 4 is the layer, enforcement agencies look for proof of origin.
69% of brands are actively preparing for the DPP, yet the same group rates its supply chain data accuracy at a median of 3 out of 5.
Only 21% run continuous, automated compliance across their suppliers, 17% still rely on spreadsheets and email, and nearly half of U.S.-selling respondents have not yet screened suppliers against U.S. government forced labour entity lists.
Supplier resistance or limited capability is the top barrier at 60%, and 63% named industry-wide supplier data standards as an accelerator, the most-cited option.
“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,” said Shameek Ghosh, CEO and Co-Founder of TrusTrace..
“But regulators ask for evidence that sits much deeper in the supply chain. 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,” Ghosh added
“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,” said Tahagod Mohamed, Senior Traceability Analyst at Brooks Running.
Mohamed further 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.”
Path Forward
The report closes with a five-stage readiness framework drawn from the brands furthest ahead: know your supply chain, extend visibility to raw material, connect data across functions, automate compliance monitoring, and build documentation readiness.
It 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 inquiry.
Download the full report at: https://trustrace.com/downloads/the-enforcement-era
Image courtesy: Brosan Textile
