More than one in five fashion brands have had shipments detained by US Customs and Border Protection (CBP), according to new survey data from traceability platform TrusTrace — the sharpest signal yet that supply chain enforcement has moved from threat to commercial reality.

The findings, released Tuesday at the Textile Exchange Conference in Vancouver, B.C., come from 57 respondents across 24 countries. The headline numbers stack up fast:

• 21% have experienced a border detention
• 58% view goods being stopped at a border as a realistic near-term risk
• Only 20% hold verified supply chain data reaching the material and farm level
• 75% don't feel fully prepared to prove material origins on demand

TrusTrace calls it a new "enforcement era" — and the timing matters. The EU Deforestation Regulation (EUDR, the bloc's law requiring proof that products aren't linked to deforestation) takes effect this year, the EU Forced Labor Regulation follows in 2027, and Digital Product Passport (DPP, the EU's upcoming product-level data disclosure requirement) rules are in the pipeline.

Where does visibility actually break down?

The report maps the drop-off precisely. Some 75% of firms said they have trusted insights from Tier 1 — their immediate suppliers and factories. That falls to 33% at the yarn and fiber level (Tier 3), and to just 20% at Tier 4, the raw material layer.

Here's the rub for sourcing teams: Tier 4 is exactly where enforcement agencies look hardest for proof of origin. The visibility gap sits directly under the regulatory spotlight.

DPP preparation tells a similar story. While 69% of brands said they're actively preparing for DPP rules, those same respondents rated their supply chain data accuracy at a median of three out of five.

Basic due diligence is lagging too. Only one-fifth of companies run continuous, automated compliance checks across suppliers; 17% still rely on spreadsheets and email. And 48% of US-based respondents haven't screened their supplier portfolios against the government's forced labor entity lists — arguably the cheapest first line of defence against a detention.

"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," said Shameek Ghosh, CEO and co-founder of TrusTrace.

"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," Ghosh added.

What should compliance teams do first?

The report — authored by sustainable fashion journalist Megan Doyle and TrusTrace industry and policy expert Pauline God — points to coordination as the biggest accelerator, while supplier resistance or limited capability ranks as the top barrier for 60% of respondents. Some 63% back industry-wide supplier data standards.

Tahagod Mohamed, senior traceability analyst at Brooks Running, flagged the practical chokepoint: "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."

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

TrusTrace closes with a five-stage readiness roadmap — know your supply chain, extend visibility to raw material, connect data across functions, automate compliance monitoring, build documentation readiness — plus a 90-day agenda featuring a baseline tier-visibility assessment, entity list screening and a documentation stress test modelled on a real CBP inquiry.

For sourcing and compliance leads, the decision is whether to start that 90-day clock now — or wait for the next detention notice to start it for them.