Supply chain traceability used to be a sustainability initiative, but in 2026 it has become a condition of trading.
Regulatory enforcement is no longer something fashion brands can plan for at a comfortable distance. Shipments are already being detained at the U.S. border, the EU Deforestation Regulation (EUDR) applies in December 2026, and the EU Digital Product Passport (DPP) is moving steadily toward becoming a mandatory market access requirement for apparel products. For compliance, sustainability, and sourcing teams, the question isn't whether your brand will be asked to prove where its materials come from, but whether you will have verified data ready when that request arrives.
TrusTrace's new report, The Enforcement Era: Fashion's Compliance Readiness in Numbers, measures where the industry stands today. Drawing on primary survey data from 57 sustainability, compliance and supply chain leaders across 24 countries, alongside in-depth interviews with Brooks Running and Komar, the report focuses on what brands are actually doing rather than what they intend to do and maps out a practical path forward for those still getting started. Download The Enforcement Era report
AT A GLANCE
The Enforcement Era shows an industry that is far more aware of traceability than ever before, yet still not ready for the enforcement now underway: 21% of brands selling into the U.S. have already had a shipment detained, only 20% hold verified data at farm level, and the average self-assessed data confidence score sits at 56%. This article walks you through the report's key findings, from where supply chain visibility breaks down and how brands manage supplier compliance, to DPP readiness, the barriers holding brands back, and the 90-day actions your brand can take now.
WHY IS TRACEABILITY NOW A TRADING CONDITION?
Regulators are now enforcing laws that require brands to prove wheir their materials come from, and brands without that proof are already paying for it.
21% of surveyed brands selling into the U.S. have had a shipment detained by U.S. Customs and Border Protection (CBP), A detention typically means four to six weeks of disruption, halted cash flow and expedited freight costs. Of the brands not yet affected, 58% see it a realistic near-term risk.
Meanwhile, the regulatory calendar keeps tightening. The EUDR and the Packaging and Packaging Waste Regulation (PPWR) apply in 2026, the EU's forced labor ban follows in 2027, and the Corporate Sustainability Due Diligence Directive (CSDDD) will apply to enterprise-scale companies in 2029. Each new deadline leaves less time to prepare.
WHERE DOES SUPPLY CHAIN VISIBILITY BREAK DOWN?
Supply chain visibility breaks down below Tier 1, where most brands know their direct factories well, but relatively few can prove where their raw materials originated.
When the survey asked brands which supply chain tiers, they hold trusted or verified supplier data on, the results showed a predictable but sharp drop-off with every step further down the chain:
- Tier 1, factory name and location: 75%
- Tier 2, subcontractor factories: 45%
- Tier 3, yarn and fiber producers: 33%
- Tier 4, raw material origin and farm level: 20%
For one quarter of brands, visibility also varies significantly across product lines, reflecting the patchwork reality of most supplier databases, while 5% currently hold no verified data at all.
Here's where Tiers 3 and 4 become critical. Under U.S. forced labor law, a rebuttable presumption applies to goods produced wholly or in part in a designated region, or by entities on the U.S. forced labor entity list, and that presumption can only be rebutted with clear and convincing evidence of origin held by the spinners, processors and farms deep in your supply chain. A brand without verified data below Tier 2 is therefore not in a position to mount a rebuttal. The report sets out how the EU’s approach compares.
TrusTrace forced labor compliance solution
HOW ARE BRANDS MANAGING SUPPLIER COMPLIANCE?
Most brands still manage supplier compliance through reactive, manual or audit-dependent processes that provide point-in-time snapshots rather than the continuous visibility enforcement now demands.
The survey found that only 21% of brands run continuous, automated compliance across all suppliers, which is the only model that scales with growing regulatory volume. A further 26% rely exclusively on third-party audits, 17% manage compliance through spreadsheets and email, and 6% have no formal compliance process in place at all, leaving them with significant unmanaged exposure at a time when enforcement is already active.
The report explains why the CSDDD’s loosened review cycle doesn’t reduce the need for continuous monitoring.
HOW READY ARE BRANDS FOR THE DIGITAL PRODUCT PASSPORT?
The DPP is the top regulatory priority in the survey, but stated preparation is running well ahead of real progress on the ground.
The Digital Product Passport, required under the Ecodesign for Sustainable Products Regulation (ESPR), is expected to require structured, verifiable supply chain data across multiple tiers for textile products sold in the EU, wherever a brand is headquartered. While 69% of respondents that list DPP as a priority, say they are actively preparing for it. Yet within that group, only 59% are fully already preparing or running pilots, a further 32% are aware but have not yet started. TrusTrace DPP solution.
The full requirements will be set out in the Textiles Delegated Act, expected in late 2027. That uncertainty understandably explains some hesitation, but supply chain mapping takes time, and brands that start now will be ready when the requirements are confirmed.
WHAT IS HOLDING BRANDS BACK?
The biggest barriers to supply chain transparency are supplier behavior, data infrastructure, internal capacity and supply chain complexity, with cost ranking notably lower than many would expect.
- Supplier resistance or limited supplier capability: 60%
- Data quality, fragmentation or disconnected systems: 52%
- Complexity of multi-tier supply chains: 50%
- Internal resource and bandwidth constraints: 48%
- Cost of technology and systems investment: 40%
When respondents were asked what would most accelerate their progress, one answer stood by a wide margin, with 63% naming industry-wide supplier data sharing standards. Rather than a call for lighter regulation, this is a call for coordination: a shared foundation that reduces duplicated effort for brands and suppliers alike.
WHAT DO THE MOST PREPARED BRANDS DO DIFFERENTLY?
The most prepared brands started early, built verified datasets, and treat traceability as an operational capability that serves the wider business rather than as a standalone compliance project.
The survey points to a clear link between confidence and depth of visibility: brands that rated their data confidence at 4 or 5 out of 5 were far more likely to hold verified data further down the supply chain, with half of this group holding verified Tier 3 data compared with just over a quarter of the rest of the sample. Because this is a small group, the figures should be read as an indication rather than a firm conclusion, but they closely reflect what the brands interviewed for the report describe.
Brooks Running explains how it runs mock detention drills giving suppliers shorter windows to prove material origin, and Komar shares how it’s supplier scorecard ties sustainability performance to order volumes and payment term.
WHAT DOES THE U.S. COMPLIANCE REALITY LOOK LIKE?
Fewer than half of U.S.-selling brands are proactively managing their forced labor enforcement exposure, and most would struggle to prove material origin today.
Among U.S.-selling respondents, 46% describe their exposure as proactively managed, while 17% rely solely on supplier declarations, which CBP has consistently treated as insufficient. Overall, 75% of these brands are only partially ready or not ready to prove material origin on demand.
Tariffs add another layer of risk, and they come from the same gap: brands that cannot verify origin below Tier 1 cannot accurately assess their tariff exposure. The full report breaks down how brands are responding to both forced labor and tariff risk.
KEY ACTIONS FOR BRANDS: A 90-DAY COMPLIANCE AGENDA
The report sets out a five-stage readiness framework, with a series of immediate actions, here are two actions you can start this week:
- Map your current tier visibility honestly. Document exactly where your verified data ends and where your exposure begins, so that you have a clear and realistic baseline to build from.
- Run a documentation stress test. Ask your team to produce the full document set for your top three materials as if a CBP inquiry arrived today, and treat the gaps you uncover as your implementation roadmap.
The full agenda, including DPP and U.S. forced labor steps, is in the report.
For more guidance on building the data foundation behind these steps, explore The Data Advantage Playbook and Unlocking DPP playbook.
FREQUENTLY ASKED QUESTIONS
What is The Enforcement Era report?
The Enforcement Era: Fashion's Compliance Readiness in Numbers is TrusTrace's 2026 research report on how prepared fashion, apparel and footwear brands are for regulatory enforcement. It is built on survey data from 57 sustainability, compliance and supply chain leaders across 24 countries, collected in the first half of 2026, together with interviews with Brooks Running and Komar.
How many fashion brands have had shipments detained by CBP?
21% of surveyed brands that sell into the U.S. reported that they have already had a shipment detained by U.S. Customs and Border Protection. Of the brands that have not yet experienced detention, 58% consider it a realistic near-term risk.
When will the Digital Product Passport apply to textiles?
The full DPP requirements for textiles will be set out in the Textiles Delegated Act under the ESPR, which is expected to be adopted in late 2027, with enforcement expected from 2029. Because the underlying data infrastructure takes an estimated 18 to 36 months to build, brands that start preparing now will be in a far stronger position.
GET THE FULL REPORT
The full report includes the complete Brooks Running and Komar Interviews, the five stage-readiness framework to your 90-days compliance agenda, the full ranking of the regulations brands are preparing for, main barriers to transparency and the UN Transparency Protocol perspective on shared data standards. Download your copy today.
TrusTrace helps brands map their supply chains from Tier 1 through to raw material origin, collect and verify supplier data continuously, and structure their documentation for enforcement scenarios, so that compliance becomes an outcome of how the business operates rather than a project that starts from scratch with every new regulation. Speak with one of our experts.
Disclaimer: This content is for informational purposes only and does not constitute legal advice. Please consult legal professionals for guidance specific to your situation.
