As tariffs shift supply chains around the globe, forced labor enforcement tightens and regulators demand deeper transparency, apparel brands are under increasing pressure to prove where their materials actually come from. Origin and content documentation alone isn’t enough anymore.
MeiLin Wan, founder and CEO of GenuTrace, has spent 20 years dedicated to traceability and security, including her role at Applied DNA Sciences, where she helped pioneer DNA tagging on cotton. Wan launched GenuTrace last year to bring scientific testing and digital traceability to the challenge of helping companies verify the content and provenance of their goods.
“My contribution and my legacy in this space is really about making traceability more accessible, and you can’t make it more accessible unless you understand all the different technology systems that have evolved over the last 20 years,” she said.
Here, Wan shares the role traceability plays in verifying Customs documentation, proving sustainability compliance and substantiating marketing claims.
HGI: Traceability used to be something companies talked about mostly in the context of sustainability and then came the Uyghur Forced Labor Protection Act. What’s traceability’s role now?
MeiLin Wan: It’s not just about forced labor anymore. With tariffs shifting and supply chains constantly being restructured, companies increasingly have to prove country of origin. You might reorganize your supply chain or tariff-engineer a product to take advantage of lower duties, but Customs authorities still need to know where the material actually came from.
Documentation alone isn’t enough, either, as anyone can produce paperwork. Customs is increasingly interested in proof on the product itself. Can you prove that the material doesn’t contain high-risk inputs and that the claimed origin is consistent all the way back to the fiber?
When you can prove origin properly, you often address multiple risks at once. You address the forced labor issue and the tariff issue at the same time.
HGI: You’ve mentioned an ‘evidence ecosystem’ as the future of traceability. What does this mean?
MW: There are many risks companies have to manage. These commonly include:
- Physical evidence: analytical testing, material verification, isotopes, forensic indicators
- Transactional evidence: purchase orders, invoices, logistics flows, production volumes
- Documentary evidence: certifications, declarations, chain-of-custody records
- Temporal consistency: whether claims remain plausible over time
- Risk context: regulatory, jurisdictional, and enforcement conditions
Companies need a framework that combines multiple forms of evidence, such as testing data, supply chain documentation, certifications and digital records.
HGI: Most importers only have visibility to their Tier 1 or Tier 2 suppliers. What problem does this present?
MW: It’s a major gap. They know where the garment was made and maybe where the fabric was produced, but they often don’t know where the yarn came from, and they definitely don’t know where the fiber originated.
If regulators ask you to prove that a product doesn’t contain material from a restricted region, you have to be able to verify that claim down to the fiber level. GenuTrace helps companies go deeper into the supply chain—testing fibers and yarns and identifying where the weak links are.
HGI: How do you approach fiber origin testing?
MW: We use isotope testing, which essentially creates a fingerprint of a material based on elements like carbon, oxygen and hydrogen that come from the soil, water and climate conditions where a crop is grown. That fingerprint can be compared against a database of samples to determine whether the fiber is consistent with a particular geographic origin.
We have a digital and physical library that we are continuously improving with samples at the farm level.
This methodology has been used for decades in food authentication. Olive oil is a classic example. Many products labeled extra virgin olive oil may allegedly contain canola or corn oils, and isotope testing can reveal that. And what about grains? Are they from Ukraine or from Russia where it might violate international policies or agreements?
Another important capability is identifying blends, as cotton from different regions is often blended together. For example, U.S. cotton could be mixed with Brazilian cotton—or cotton from a restricted region could be mixed in smaller quantities. Testing can detect those inconsistencies.
HGI: How do blends drive the urgency to start traceability at the raw material stage?
MW: Once materials are co-mingled and turned into yarns and fabrics, the identity of the original material becomes much harder to determine. That’s why when testing, we start from the source and work forward, rather than trying to reconstruct the supply chain after the product is already made.
If you begin at the farm or fiber stage, you can build a system that follows the material through the entire supply chain. Trying to prove traceability after the fact is always more expensive and more time-consuming.
HGI: Climate events and supply disruptions are on the rise. Are you seeing an increase in substitution and mislabeling as a result?
MW: Absolutely. If flooding or extreme heat reduces cotton production in a region, suppliers may need to blend fibers from other locations to boost reduced supply or maintain a usable quality.
HGI: Due to incoming legislation, the industry is on high alert for greenwashing. But while greenwashing is often framed as intentional deception, is that always the case?
MW: In practice, many problematic claims arise from something more structural: evidentiary mismatch. Narratives extend beyond what underlying data can defensibly support, and selective metrics obscure tradeoffs. When documentation substitutes for verification and precision is assumed, uncertainty persists.
HGI: How does all this traceability fit into a digital system?
MW: Testing alone doesn’t solve the problem unless it’s connected to a digital infrastructure. That’s why we partnered with Kinset to create QR codes, which we call digital product passports in Europe. These systems allow companies to store and organize all the evidence related to a product in one place, including test results, certifications and origin data.
Consumers just scan a QR code to see certain information about the product, while brands and supply chain partners can access deeper levels of data.
Historically, this information existed in spreadsheets and PDFs scattered across multiple systems. A digital platform allows companies to organize and communicate that evidence much more effectively.
