More than one in five fashion brands have had shipments detained by U.S. Customs and Border Protection, according to new data from supply chain traceability platform TrusTrace released Tuesday at the Textile Exchange Conference in Vancouver, B.C.

The survey of 57 respondents across 24 countries frames the findings as evidence of a new enforcement era — one in which most brands cannot yet prove where their materials come from. Just 20 percent of firms hold verified data reaching upstream to material and farm level, the layer enforcement agencies scrutinize most heavily for proof of origin.

The commercial exposure is immediate. Beyond the 21 percent who have already experienced detentions, 58 percent consider having goods stopped at a border a realistic near-term risk. Three-quarters said they do not feel fully prepared to prove material origins on demand.

How deep does visibility actually go?

Confidence collapses below Tier 1. The report found:

• 75 percent of respondents have trusted insights from immediate suppliers and factories
• 33 percent have visibility at the yarn and fiber level, or Tier 3
• 20 percent hold actionable data from Tier 4 raw material suppliers

The timing sharpens the gap. The EU Deforestation Regulation takes effect this year, the EU Forced Labor Regulation follows in 2027, and Digital Product Passport requirements are in progress. TrusTrace argues the delta between regulatory awareness and operational preparedness is already taking a commercial toll.

Is the industry ready for Digital Product Passports?

Not yet, by its own assessment. While 69 percent of brands said they are actively preparing for DPP regulations, those same respondents rated their supply chain data accuracy at a median of three out of five.

Basic due diligence is lagging further still. Only one-fifth of companies run continuous, automated compliance across their suppliers, and 17 percent still rely on spreadsheets and email. Among U.S.-based respondents, 48 percent have never screened their supplier portfolios against the government's forced labor entity lists — a first-line defense against detention.

The report's authors, sustainable fashion journalist Megan Doyle and TrusTrace industry and policy expert Pauline God, identified coordination as the biggest accelerator for progress. Supplier resistance or limited capabilities rank as the top barrier for 60 percent of respondents, while 63 percent cited industry-wide supplier data standards as an accelerator.

What do enforcement officials actually ask for?

Shameek Ghosh, CEO and co-founder of TrusTrace, said the evidence bar has moved deeper into the chain.

"Enforcement is no longer on the horizon. It is here. Border officials look at evidence to decide which goods move and which goods they hold. The industry has made real progress at Tier 1. But regulators ask for evidence that sits much deeper in the supply chain," Ghosh said. "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."

Tahagod Mohamed, senior traceability analyst at Brooks Running, pointed to a structural problem: the absence of a defined standard for documentation at each tier.

"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," Mohamed said. His guidance to suppliers: "Provide as much as you can to show how the raw material was produced, processed, transported and paid for to make the final product."

What does the roadmap propose?

The report closes with a five-stage readiness framework drawn from the practices of the most advanced brands: know your supply chain, extend visibility to raw material, connect data across functions, automate compliance monitoring and build documentation readiness.

It also lays out a 90-day compliance agenda with a realistic baseline for tier visibility, entity list screening and a documentation stress test modeled on a real CBP inquiry.

With EUDR live this year and the Forced Labor Regulation arriving in 2027, brands that have not yet screened their suppliers against entity lists or mapped beyond Tier 1 face a narrowing window to build the evidence base regulators now demand.