This case study featuring Primark is taken from the latest industry playbook, The Data Advantage. Get your copy to read this and more case studies with brands and suppliers.
Primark’s traceability and data strategy is based on the company’s need to comply with regulations on the one hand, and achieve environmental and social targets on the other. While their legal and compliance teams play a central role in interpreting regulations, the representatives explain that implementing them requires close collaboration across the business — including sourcing and production teams, who manage supply chain mapping, data collection and ongoing progress tracking.
Since 2022, the expanding regulatory data needs and Primark’s transparency efforts have led to a new approach to supply chain data collection and supplier management. An onboarding process has been underway to train all of Primark’s new and existing suppliers as to the brand’s exact data requirements, why the data is needed and what it will be used for.
This process has thrown up unforeseen challenges and opportunities, but is essential, as explained by Cari Atkinson, who leads product traceability:
“In the past Excel spreadsheets served a purpose, but they were not scalable or efficient for suppliers across multiple regions–and suppliers in multiple countries were being asked for the data twice.”
Primark plans to onboard their full clothing and textile supplier base to the TrusTrace platform by the end of 2025. Atkinson explains the dual ambitions for mapping and onboarding the supply chain:
“Our Primark Cares commitments are public and span across the business; we knew traceability would be an enabler to help us achieve those. Then, with regulations and legislation we are subject to all, including UFLPA, the German Supply Chain Act, ESPR and DPP, in 16 to 17 markets.”
The approach has been to gather the required data via Tier 1:
“We’ve been getting Tier 2 and 3 information from [our] Tier 1 suppliers, who run as a business extension of Primark sourcing...”
“Outside of our nominated supply chains we would gather that information directly ourselves.”
Although it is clear that the regulations and legislation will demand greater supply chain data transparency and accessibility, it’s not clear exactly what data will be needed when, and in what form:
“The challenge is understanding the legislation and regulations – it can be quite unclear what’s required and how to interpret them. Take EUDR–it was supposed to go live but was postponed and clarifications and requirements are still coming out… We’ve tried to start in advance of that, though.”
The lack of clarity is leading to a more complicated data burden as brands try to get started despite gaps in the requirements:
“For DPPs we know textile and furniture will be in scope… but the specific legislative details are still being finalised. In the meantime brands are trying to ‘solve for’ the same problems, but in different ways.”
Investing in Traceability
Atkinson explains the expansion of skills the new data demands require:
“For Primark, extra resources are required for enhanced traceability and compliance— this couldn’t be absorbed into the business as it stood. We have a dedicated traceability team that went from 1 to 13 people in 3 years.”
Primark has a 13 member core traceability team with colleagues on the ground in China, India and Bangladesh, training and working with the suppliers on a daily basis to enable them to gather data and work on data quality.
Operationalizing Systematic Data Collection
The increasing data burden on suppliers is the reason this Playbook is being written, and Primark admits this poses difficulties. There have been supplier challenges, according to Atkinson, and introducing the new traceability and data collecting systems takes time:
“We do supplier training on the ground where onboarded suppliers speak in panel discussions to share how they’ve managed the data burdens and the pitfalls…”
“We try to spread out what we ask for [in data terms]. We have taken a phased approach to suppliers onboarding and prioritised cotton, then expanded to numerous other fibres…”
Despite the additional work and process change, Roseann Hickey, Director of Sustainability, Quality and Compliance, says there are extended benefits:
“Suppliers are benefitting from systemizing their [own] supply chain and avoiding Excel; they [now] have visibility of [utilization of] their suppliers and can evaluate that.”
Beyond Compliance - Strategic Opportunities
Building on their mapping of Tier 1 suppliers and their supply chains, the company has begun linking purchase orders (POs) to the mapped suppliers, and examining what is being produced where, in real time. Atkinson explains:
“We have 60 suppliers connected to purchase order tracing and the plan is to transition all suppliers to live tracing so that as soon as the purchase order is confirmed...they can give us the view of material and production flow.”
Hickey explains how linking purchase orders to suppliers and therefore the material flows in the supply chain is providing additional insights:
“Purchase Order tracing shows us the facilities being utilised in the supply chain and who has the potential to have the biggest impacts.”
As this expands, Hickey explains the impact on suppliers:
“Having the POs linked to the supply chain map is going to be a game changer – it won’t only help with visibility but it will help suppliers to challenge the number of suppliers they’re working with upstream and optimise.”
Supply Chain Visibility beyond Tier 1 is managed via Tier 1 suppliers:
“Since Tier 1 places orders with Tier 2 they have the most leverage up the supply chain. That’s why it works best this way–that’s where the commercial relationship is.”
Regarding how the data might shape Primark’s sourcing decisions, Hickey adds, “There are lots of strategic conversations happening but we are still gathering information.”
What are the opportunities beyond live production information?
“It helps us to see how traceability ties into lots of other parts of the business, including the carbon team, sourcing team, quality and compliance, product sustainability and materials changes.”
“With Primark's 2030 targets, as well as regulations including DPPs, we are working closely together across teams, so having the supply chain in a live system is the foundation of everything we are trying to do.”
Like many growing companies, Primark faces the challenge of reducing impacts while continuing to expand. Therefore, identifying the brands’ emissions ‘hotspots’ (which are invariably in Scope 3–supply chain facilities) is crucial. Hickey adds, “Scope 3 carbon is the biggest impact, and having the visibility of where the biggest volume of production is will be invaluable.”
Fortified Business
Regarding strategy and deployment, Hickey says the tracing and data approach is driven from the executive level.
“When we launched this we had a huge amount of support from the Chief Product officer and we got the buy-in and investment in Cari and her team of thirteen. That’s what drives this.”
“Because we had everybody [in Primark] invested, our suppliers invested [in it] themselves. We’ve been working with many of our suppliers for over 20 years–our tier 1 suppliers are like an extension of the business.”
How is Primark Using the Data?
Hickey highlights a couple of data examples related to supply chain optimization and enhanced compliance. For live purchase order tracing:
“Having visibility of what’s made where and in what volume helps us manage production allocation more effectively…”
“It means our sourcing team can work
in closer partnership with Tier 1
suppliers, for example, by identifying when not all mapped suppliers are
being fully utilized.”
From a wider business point of view:
“There will be multiple use cases, for example CSRD, the DMA (Digital Markets Act) requirement; and a lot of the legislation requires the ability to demonstrate how you are doing due diligence–not to just say we have
done it.”
While there is still uncertainty around final data requirements across all regulations, Primark says it is investing in systems that meet current needs and are flexible enough to adapt. Traceability and data collection efforts are a significant drain on business resources, so their ambition is to use the data for supply chain optimisation, better allocation of production and identification of risks – making the data work for the business, beyond mere compliance.
In closing, Cari Atkinson and Roseann Hickey explained that in the absence of a standardised approach to data requirements and collection methods across the industry, they interact with the likes of Textile Exchange and other NGOs, who partner with other brands (many of whom share Primark’s suppliers) to ensure they are in line with the market and the industry, rather than attempting to set up their own stand-alone systems or approaches. In this data and traceability effort, Hickey concludes:
“We want to be part of the industry.”
Primark is not alone in its calls for unity and harmonisation, as is revealed in the following brand and supplier interviews; nor is Primark the sole brand aiming to extract more value and insight from compliance data to make better business decisions.
Get more insights from brands including Adidas and Hugo Boss in the 4th industry playbook, The Data Advantage. Download your copy.
