new report

The Enforcement Era

Our latest report, "The Enforcement Era: Fashion's Compliance Readiness in Numbers", is now available. Built on primary data from 57 sustainability, compliance and supply chain leaders across 24 countries, it measures what fashion brands are actually doing to meet new regulations, not what they intend to do.

Download your copy to see where the industry really stands, what delayed action is already costing brands, and the practical steps to close the gap.

Traceability is now a trading condition

For years, supply chain traceability was treated as a sustainability initiative. In 2026, it's a condition of doing business. Forced labor and due diligence laws are accelerating on both sides of the Atlantic, with the EU Deforestation Regulation and the Digital Product Passport close behind.

The consequences are already here. Brands that can't prove where their materials come from are facing detained shipments, customs delays and lost market access, and they are losing sourcing flexibility.

This report takes the temperature of an industry that is more aware of traceability than ever, and measures how much real progress has been made. Some findings make for uncomfortable reading. All of them are actionable, and every deadline is still achievable for brands willing to start now.

The Readiness Gap in Numbers

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21% of brands selling into the U.S. have had a shipment detained by U.S. Customs and Border Protection (CBP)
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20% of brands hold trusted data at raw material and farm level, down from 75% at Tier 1 factories
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63% say industry-wide supplier data standards would accelerate progress most
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48% of U.S.-selling respondents have not yet screened suppliers against U.S. government forced labor entity lists
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17% still manage supplier compliance through spreadsheets and email
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60% cite supplier resistance or limited capability, the most common barrier to progress
Source: The Enforcement Era: Fashion's Compliance Readiness in Numbers, TrusTrace 2026. Survey of 57 fashion, apparel and footwear respondents across 24 countries.

What's in the report?

The report follows the readiness gap from the regulations brands are preparing for to the raw materials they still can't see, with first-hand accounts from Brooks Running and Komar and perspectives from UNECE and PIP Global Safety.

Where is the industry stuck?

Brands are preparing for nine regulations at once, but not with equal urgency. The report ranks where attention is going, and where high priority hasn't turned into progress.

It also breaks down the barriers brands say are holding them back, from supplier capability and fragmented data to internal bandwidth and buy-in, and what it will take to move past them.

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How deep does visibility go?

Most brands can name their direct factories. Far fewer can follow their products back through subcontractors, yarn and fiber producers, and on to the farm.

The report maps verified visibility tier by tier, shows where it drops off, and explains why the gaps furthest upstream have stopped being a future concern and become an immediate enforcement risk.

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What did early movers do differently?

Brooks Running stress-tests its suppliers with mock detention drills, and suppliers now submit a complete document set within two weeks on average. Komar rewards suppliers that perform well on sustainability with higher order volumes and better payment terms.


The report also looks at four years of U.S. forced labor enforcement, how affected brands are managing detention risk, tariffs and proof of origin, and the lessons others can still act on.

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What should happen in the next 90 days?

A five-stage readiness framework built on what the most prepared brands have in common, plus a 90-day agenda: baseline your tier visibility, screen suppliers against entity lists, and stress-test your documentation as if a CBP inquiry arrived today.


Pauline God, TrusTrace's Industry and Policy Expert, also explains what sets the most data-confident brands apart.

Download report
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Featuring Contributions From

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Megan Doyle

Contributing Editor; Sustainable Fashion Journalist and Consultant
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Pauline God

Managing Editor; Industry and Policy Expert, TrusTrace
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Melanie Hughes

Reviewer and Co-Editor; CEO and Founder, THEIA
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Tahagod Mohamed

Senior Traceability Analyst, Brooks Running
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Dr. Thiwanka De Fonseka

Chief Sustainability Officer, Komar
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Christian Hudson

Chair, Team of Specialists on ESG Data in Value Chains, UNECE
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Julie Robertson

Director of Supplier Management, PIP Global Safety

SEE WHERE YOU STAND

Enforcement is already here. How ready you are when the next deadline arrives is up to you. Download The Enforcement Era to benchmark your readiness against the industry and start closing the gap.
Download report