Responsible sourcing is an imperative for sustainable procurement practices. You must know your sources’ origins throughout manufacturing aka supply chain/value chain, from seeds to sales. Regulations demand that you must prove diligence on all levels. Due diligence is a careful review and assessment to identify risks, confirm facts and support informed decision-making. Traceability of all components of the entire product “bill of materials;” comprehensive list of all the raw materials, components, parts, and quantities required to manufacture, assemble, or build a product. So many companies are in the process of understanding what traceability means to them and how to incorporate into business processes without undue burden and costs.
That same confusion happens to entrepreneurs building traceability-adjacent businesses, sustainability managers stepping into a new role, sourcing teams suddenly handed a UFLPA, EUDR, or CSDDD compliance mandate, or founders trying to build responsible supply chains from day one. Traceability has become one of those words that everyone uses but is never defined in the same way.
Below we offer a practical orientation to help you understand what traceability is, where real complexity lives, and how to start building something that will prove diligence and improve over time.
First: Get Clear on What Problem You Are Actually Solving
This sounds obvious, but it is the step most people skip. They hear “traceability” and immediately start looking at platforms, certifications, and technologies. But traceability is not the product. It is a capability, and what you need it to do shapes everything that follows.
There are at least four distinct reasons organizations pursue traceability, and each presents its own challenges:
- Regulatory compliance: proving to Customs, EU authorities, or other regulators that your bill of materials does not originate from restricted regions or involve forced labor.
- Sustainability claims: substantiating that your cotton is organic, Better Cotton, recycled, or otherwise responsibly sourced.
- Brand protection: ensuring that what you say is in your product is actually in your product, and that your suppliers are not substituting materials.
- Supply chain visibility: simply knowing who is in your supply chain, where materials come from, and which tier of supplier touches your product.
These four challenges often overlap, but they require different tools, different evidence standards, and different partnerships. A company solving for regulatory compliance under UFLPA needs defensible, scientific proof of origin. A company solving for supply chain visibility might start with a supplier mapping exercise and a digital platform. Conflating them wastes time and money.
Start by completing one sentence: “We need traceability because…”. If you cannot finish that sentence clearly, the tools you are looking at will not solve your problem.
Second: Understand the Supply Chain You Are Actually Working With
One of the most common mistakes newcomers make is approaching traceability as if supply chains are linear. Farm to gin to spinner to mill to brand: a clean sequence of handoffs, each documented, each traceable. That is not how global textile supply chains work.
In the case of cotton, it is a fiber that can be blended with other fibers to form yarn. Fibers from multiple cotton farms and even multiple countries are mixed at the ginning stage, at the spinning stage, and sometimes again at the mill. A fabric that is certified as organic may have been spun alongside conventional fiber. A garment sold as 100% cotton may have passed through six countries and changed hands eleven times before it reaches the retailer. At each of those transitions, the identity of the original material becomes harder to verify, not because anyone is acting in bad faith, but because the system was built for efficiency, not traceability, which causes fiber identity loss.
What this means practically: you need to map your supply chain before you can trace it. That means identifying not just your Tier 1 suppliers (the ones you have direct contracts with); but also Tier 2, the fabric mills (knitters and weavers); ideally Tier 3 (the spinners); and Tier 4, the raw material processors and farms. For most brands, Tier 2 is already murky. Tiers 3 and 4 are often completely unknown.
As Robert Antoshak, who has spent decades advising brands on responsible sourcing, puts it: the value of supply chain mapping is not just knowing where materials come from. It is knowing what you do not know and building that into your risk assessment from the beginning.
“You cannot trace what you have not mapped, and the mapping itself is often the most revealing part of the exercise — not because it shows you what you know, but because it shows you exactly where your knowledge ends. That is where your real risk lives.”
—Robert Antoshak, Vice President, Grey Matter Concepts
Third: Know the Three Layers of Traceability, and Do Not Confuse Them
When discussing traceability, people are typically referring to one of three distinct concepts, and confusing them can create significant problems later.
Layer 1: Documentation and Chain of Custody
This is a paper trail such as transaction certificates, supplier declarations, certification records, and purchase orders that follow material through the supply chain. It is necessary. It is also not sufficient on its own. Documentation tells you what was claimed at each step. It does not tell you whether the physical material in your product matches those claims.
Layer 2: Digital Platforms and Data Systems
Tools like blockchain-based systems, supply chain mapping platforms, Digital Product Passport infrastructure help to organize and transmit the documentation layer. They make it more accessible, more auditable, and harder to falsify. But they are only as dependable as the data fed into them. Garbage in, garbage out. A Digital Product Passport that records an unverified claim is just a more sophisticated way of recording an unverified claim.
Layer 3: Physical Verification
This is where science enters. Isotopic testing, genomic analysis, molecular markers are some of the technologies that can verify the physical origin or composition of a material, independent of what the documentation says. This is the layer that closes the gap between declared and actual. It is also the most expensive and technically complex layer, which is why it tends to come last in most organizations’ traceability journeys, even though it is often where the real risk lives.
You do not necessarily need all three layers from the beginning of your program. But you do need to understand each layer’s complexity to be sure it is doing its job and to reveal where your program may have blind spots.
Fourth: Start Where the Risk Is, Not Where It Is Easy (low hanging fruit)
There is a natural tendency, especially for entrepreneurs and new role holders, to start with what is accessible. You sign up for a certification. You implement a supplier questionnaire. You buy a platform. These are reasonable steps, but if they are not targeted at your actual risk, they give you the feeling of progress without the substance of it.
A more useful framework: start by asking where, in your supply chain, something could go wrong in a way that may be high risk and potentially cost you most. That might be a regulatory detention at the port.
“By the time a shipment is detained, the question is no longer whether you have traceability — it is whether you can produce the evidence in thirty days. I have watched importers scramble to reconstruct a supply chain backward from a container sitting at the port, and I have watched importers hand CBP a complete package in a week because the testing and documentation existed before the goods ever shipped. Same regulation, completely different outcomes. The difference was decided months earlier,” stated Nunzio Defilippis, Licensed Customs Broker and Co-CEO, CargoTrans.
A journalist who traces your “sustainable” cotton back to a farm with labor violations. A brand partner who asks for evidence you cannot produce. A customer complaint you cannot investigate because you do not know who processed your product’s fiber.
Once you have identified those pressure points, you can work backward to figure out what traceability capability would actually address them. That discipline, starting from risk rather than starting from tools, is what separates organizations that build traceability programs that work from organizations that accumulate certifications that look good but do not hold up.
Fifth: Build Relationships Before You Build Systems
Your traceability program is not just about systems and transactions, and there are plenty of companies out there who offer a multitude of technical tracking systems and transaction documentation recorders. Here is the thing about traceability that no technology vendor will tell you: it is fundamentally a relationship problem, not a technology problem. The most sophisticated platform in the world cannot trace your cotton if your Tier 2 mill does not trust you enough to share their supplier relationships. The most precise isotopic test cannot be run if your ginning partner has never heard of it and sees no reason to cooperate.
The brands and organizations that have genuinely advanced supply chain transparency share a common trait: they invested in relationships with their suppliers before they invested in systems. They explained why traceability mattered, not just for compliance, but for commercial stability, for market access, for the supplier’s own reputation. They made it a partnership, not an audit. Your suppliers are a great asset and need to be treated that way.
For entrepreneurs building in this space, this is a crucial insight. Your value proposition cannot be “we will catch your suppliers doing the wrong thing.” It has to be “we will help you prove to your customers and regulators that your supply chain does the right thing.” Those are different conversations, and they produce very different kinds of cooperation.
Sixth: Be Honest About What You Can and Cannot Claim
The regulatory environment around supply chain transparency is moving fast. UFLPA in the United States, the EU Forced Labor Regulation taking full effect in 2027, the Digital Product Passport requirements coming for textiles. These frameworks share a common demand: verifiable proof, not documented assertions.
Recent U.S. trade enforcement developments further reinforce this trend. In early June 2026, a new Executive Order on customs enforcement signaled a broader shift away from enforcement focused solely on products or countries of origin and toward scrutiny of importers, supply chains, ownership structures and origin substantiation. The Order directs Customs and Border Protection (CBP) to expand supply chain disclosure requirements and increase focus on issues such as forced labor, rules of origin, illegal transshipment and importer accountability. The practical implication is clear: organizations will increasingly be expected not only to make claims about where materials come from, but also to support those claims with reliable documentation and, where appropriate, independent verification.
What this means for anyone building a traceability program today is that the standard is rising. Claims that were accepted two years ago such as “our cotton is certified Better Cotton” or “our supplier has signed a code of conduct”, are no longer sufficient in this new enforcement-driven, claims substantiation environment. Regulators and buyers increasingly want to know: if I tested this product, would the results match what you are claiming?
The honest answer, for many organizations, is we do not know. And that is actually a fine place to start, if you acknowledge it, treat it as a gap to close rather than a truth to hide, and build toward a higher standard incrementally. What is not fine is making claims you cannot substantiate, or assuming that documentation-layer compliance will protect you when physical verification becomes the norm.
“A lot of companies are carrying more regulatory risk than they realize right now, because the gap between what they claim and what they can physically prove has never been tested. That window is closing. UFLPA enforcement is accelerating, the EU Forced Labor Regulation goes into full effect in 2027, and buyers are already asking harder questions than regulators are. The time to get rigorous about what you can and cannot substantiate is before someone else forces the conversation.”
—Ron Sorini, Principal, Sorini Strategic Advisors
A Practical Starting Point: Five Questions to Ask Before You Do Anything Else
If you are genuinely new to this space and want a place to begin, start with these five questions. Not a technology evaluation. Not a certification audit. Just honest answers.
- What am I actually trying to prove, and to whom? (Regulator? Brand partner? Consumer? Investor?)
- How far back in my supply chain can I currently go, with documentation I actually have in hand?
- Where is the weakest link? Is it the point where my supply chain knowledge goes from solid to vague?
- Which of my suppliers would cooperate if I asked for more transparency, and which ones would resist?
- If a regulator or a journalist asked me to prove a claim about my supply chain tomorrow, what evidence could I actually produce?
The answers to those five questions will tell you more about where to start than any platform demo or certification brochure. They will also reveal which of the three traceability layers—documentation, data systems, or physical verification—needs your attention first.
There Is No Perfect Starting Point . . . But There Is a Wrong One
The wrong starting point is doing nothing because the problem feels too large. Traceability is not an all-or-nothing proposition. You do not need a fully verified, isotopically tested, blockchain-documented supply chain on day one. You need a clear understanding of your risks, an honest inventory of what you currently know and do not know, and a commitment to closing gaps systematically over time. And remember your suppliers are your partners not your adversaries.
The right starting point is different for everyone. For a founder building a sustainable brand from scratch, it might mean designing your supplier relationships with traceability requirements built in from the beginning, not retrofitted later. For a new sustainability manager, it might mean spending your first ninety days mapping Tier 2 before you talk to anyone about platforms or certifications. For an entrepreneur building a traceability technology or service, it might mean spending time on the factory floor and at the gin before you write a single line of code or marketing copy. You must get out there and meet your suppliers, as many as possible, communicate to them all regularly, and make them part of your vocabulary.
The best practitioners in this field, whether representing brands, suppliers, or technology providers, all share a common approach: they begin with curiosity about how supply chains actually function, rather than assumptions about how they should function. More than any certification or technology, this mindset is what makes traceability meaningful. Understanding your supply chain begins with your bill of materials and every manufacturing partner involved, from farmers to exporters and importers.
About the Authors
MeiLin Wan is CEO and Founder of GenuTrace and a supply chain traceability pioneer with over 20 years of experience in forensic verification and material authentication. She has set new benchmarks in the textile industry through her work with molecular markers, isotope analysis, and genomic testing, executing programs across the United States, Egypt, Asia, and Australia spanning cotton, wool, down, leather, recycled polyester, and sewing thread. Through GenuTrace, she leads a boutique consultancy that empowers brands, manufacturers, and retailers to move from declared transparency to verifiable, defensible proof through forensic fiber analysis, isotopic testing, and multi-layer verification frameworks aligned with UFLPA, EUDR, and the EU’s Digital Product Passport. She can be reached at sales@genutrace.com.
David Uricoli is Lead Partner Consultant at Gherzi USA, part of the globally respected Gherzi Textil Organisation, specializing in ESG, responsible sourcing, and supply chain traceability across the fashion and apparel industry. He also serves as Principal of Uricoli Consulting Inc., where he collaborates with companies and organizations to build corporate responsibility and sustainability programs that create better opportunities for workers and their communities while protecting the environment. With more than 35 years of experience, he partners with brands and manufacturers to drive measurable improvements across end-to-end supply chains, spanning social compliance, operational due diligence, and manufacturing process optimization, with a particular focus on fostering the supplier relationships that make traceability programs both practical and durable.
