Forced-labour enforcement is exposing a critical weakness in fashion supply chains: brands often know their garment factories but cannot rapidly prove where cotton, fibres and other raw materials originated.
More than one in five fashion companies selling into the US have experienced shipment detention by US Customs and Border Protection, according to new research from supply-chain traceability provider TrusTrace. Its Enforcement Era study surveyed 57 sustainability, compliance and supply-chain leaders across 24 countries.
Visibility collapses upstream
While 75% of respondents hold trusted data at Tier 1 factory level, only 20% have comparable information at raw-material or farm level. EcoTextile reports that 75% were not fully prepared to prove material origin on demand.
The weakness is operational as well as technical. 48% of respondents selling into the US had not screened suppliers against US government forced-labour entity lists, while 17% still managed supplier compliance mainly through spreadsheets and email. Supplier resistance or limited capability was cited by 60% as a major barrier.
Enforcement replaces disclosure
The US Uyghur Forced Labor Prevention Act applies a rebuttable presumption against goods produced wholly or partly in Xinjiang or by listed entities, placing the evidentiary burden on importers. CBP can therefore require documentation reaching deeper than the finished-garment supplier.
Europe is moving in the same direction. The EU Forced Labour Regulation applies from December 14, 2027, prohibiting products made with forced labour from being placed on or exported from the EU market.
Competitiveness takeaway
For textile exporters, factory certification alone will increasingly be insufficient. Buyers need evidence linking cotton or fibre → yarn → fabric → processing → garment → shipment, supported by supplier identities, transaction records and origin documentation.
This creates a competitive opportunity for vertically integrated groups. Mills that can provide purchase-order and batch-level traceability back to fibre origin, together with automated risk screening and auditable evidence, can reduce detention risk for buyers.
Traceability is therefore becoming more than compliance infrastructure: it is becoming a trade-enablement capability capable of influencing supplier selection, customs clearance and market access.
