TrusTrace warns 21% of US-bound brands face detentions

TrusTrace has published a report on fashion brands' readiness to comply in the US market. The study found that 21% of surveyed brands selling into the US have had shipments detained.

Based on responses from 57 sustainability, compliance and supply chain leaders across 24 countries, including 40 full responses, the report highlights a gap between companies' awareness of tightening trade and sourcing rules and their ability to prove material origins when challenged by border authorities.

One of the sharpest findings is how visibility weakens deeper into supply chains. While 75% of respondents said they hold trusted data on Tier 1 factories, that falls to 33% at Tier 3, covering yarn and fibre, and to 20% at Tier 4, covering raw materials and farm level.

That matters because evidence from lower tiers is often central to origin checks and forced labour scrutiny. The survey also found that 75% of brands are not fully ready to prove material origin on demand.

Detention risk

The research suggests shipment detention is no longer a theoretical issue for companies shipping goods into the US. Among brands that had not yet faced a detention, 58% said they viewed it as a realistic near-term risk.

Basic compliance processes also appear uneven. Only 21% of respondents said they run continuous, automated compliance checks across suppliers, while 17% still rely on spreadsheets and email. Nearly half, 48%, of respondents selling into the US said they had not screened suppliers against US government forced labour entity lists.

The report places these findings within a broader regulatory shift affecting the fashion sector. Rules linked to deforestation, packaging waste, forced labour and digital product information are making traceability a trade requirement rather than a voluntary sustainability exercise.

Preparation for Digital Product Passports is one example. TrusTrace found that 69% of brands are actively preparing for DPP requirements, yet that same group rated the accuracy of their supply chain data at a median of three out of five.

Supplier pressure

The biggest reported obstacle was supplier resistance or limited capability, cited by 60% of respondents. At the same time, 63% said industry-wide supplier data standards would do most to help companies move faster, making it the most commonly cited accelerator in the survey.

The findings reflect a common problem in global apparel supply chains, where brand visibility often fades after the final manufacturing stage. Many businesses can identify the factory assembling a garment but struggle to document the origin and movement of fibres, yarns and raw inputs across multiple countries and subcontractors.

The study was written by journalist Megan Doyle and edited by Pauline God, Industry and Policy Expert at TrusTrace. It also includes interviews with Brooks Running and Komar, as well as contributions from Christian Hudson of the UN Centre for Trade Facilitation and Julie Robertson of PIP Global Safety.

Shameek Ghosh, Chief Executive Officer and Co-Founder of TrusTrace, said the report showed enforcement pressure had already reached the point of affecting trade flows.

"Enforcement is no longer on the horizon. It is here. Border officials look at evidence to decide which goods move and which they hold. The industry has made real progress at Tier 1. 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," said Shameek Ghosh, Chief Executive Officer and Co-Founder of TrusTrace.

Documentation gaps

The report argues that one practical difficulty for suppliers is the lack of a single accepted standard for what counts as sufficient proof at each stage of production. That can leave mills, processors and raw material suppliers unsure how much documentation they need to provide to meet customer and customs expectations.

Tahagod Mohamed, Senior Traceability Analyst at Brooks Running, described that uncertainty as a major challenge for suppliers responding to brands' data requests.

"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. 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," said Tahagod Mohamed, Senior Traceability Analyst at Brooks Running.

According to the methodology, the survey covered fashion, apparel and footwear brands globally, with percentages calculated only from respondents who answered each question. Base sizes therefore varied from 24 to 55, and the sample also included a small number of manufacturers, mills and industry bodies.

The report sets out a five-stage readiness framework based on companies it identifies as more advanced in compliance work: understanding the supply chain, extending visibility to raw materials, connecting data across internal functions, automating compliance monitoring and preparing documentation for scrutiny.