For years, supply chain conversations centered on cost, capacity and speed. Today, they’re increasingly centered on something else: proof. As U.S. import scrutiny intensifies under the “Strengthening Customs Enforcement” Executive Order, sourcing executives are facing a new reality where documentation alone may no longer be enough. Regulators are taking a more connected approach to customs compliance, forced labor, origin verification and sanctions enforcement, raising expectations for what importers—and their suppliers—can substantiate.
The shift is prompting brands to rethink the questions they ask throughout their supply chains. Industry leaders say the companies best prepared for what’s ahead will be those that can connect digital records with physical evidence, respond quickly when shipments are challenged and replace assumptions with verifiable data. From strengthening supplier conversations to building more resilient traceability systems, traceability experts share their perspectives on the biggest challenges to achieving full traceability, and the best path forward to mitigate risk.
Rebecca Brocato
Chief Government Affairs Officer – Americas
Oritain
On what buyers need to ask suppliers today: The Executive Order is a clear signal that this issue now has attention at the highest political levels, but it is the combination of policy and enforcement activity that should be driving action. Businesses are seeing new enforcement actions rolled out in real time, which demonstrates that customs enforcement continues to be a significant area of focus. Sourcing executives should be having conversations with suppliers about whether they are prepared for increased scrutiny around sourcing, origin claims and compliance.
Regulators are looking beyond individual commodities or compliance frameworks and are increasingly treating customs compliance, supply chain due diligence, sanctions enforcement and origin verification as interconnected risks. The question suppliers should be asking themselves is not whether enforcement will increase, but whether they can confidently stand behind the claims being made throughout their supply chains.
On the threat to business as usual: In the U.S., this is increasingly being driven through a broader trade enforcement agenda involving agencies such as the Department of Justice (DOJ), Department of Homeland Security (DHS) and customs authorities, creating greater scrutiny of sourcing claims, origin declarations and import compliance. Recent enforcement activity in the timber sector provides a strong example. Cases such as Boise Cascade demonstrate how authorities are using longstanding legislation, including the Lacey Act, to pursue issues linked to origin misrepresentation, trade fraud and duty evasion.
Businesses should expect greater convergence between forced labor regulations, sanctions regimes, tariff enforcement, customs scrutiny and broader trade compliance requirements. The organizations best positioned for this environment will be those that recognize supply chain integrity is no longer a challenge tied to a single regulation, commodity or market. It is becoming a cross-cutting business risk that spans multiple enforcement priorities.
On what verification looks like in practice: Preparing for this shift requires moving beyond document-based compliance alone and building greater confidence in where products and raw materials genuinely come from across the entire supply chain.
Julianne Thibodeaux
Global Head of Commercial
FibreTrace
On what buyers need to ask suppliers today: The most useful advice I’ve heard came from a supplier speaking to other suppliers: stop selling capacity, start selling proof. That shift captures where the market is heading. Sourcing executives should be asking their suppliers a simple question—can you prove material origin at the product level, not just describe it on paper? The suppliers who can answer yes are about to become far more valuable than the ones competing on volume alone.
This is not a one-sided demand. Brands don’t move forward without their suppliers, and suppliers grow faster when they can hand a brand something better than a document. When a supplier can offer verified proof of origin, they’re giving the brand something it can stand behind publicly—and giving themselves a commercial edge in the process. The conversation shouldn’t be framed as a new burden passed down the chain. It should be framed as a shared advantage: the supplier who brings proof wins more business, and the brand who sources it can back every claim it makes.
On the threat to business as usual: Certificates and traceability records are important pieces of the puzzle, but confirming they match what’s physically in the product is harder than most companies expect. Teams lean heavily on third parties, then spend significant resources triangulating certification data against other data points to close the gaps. As enforcement sharpens, that gap between documentation and material becomes an exposure few brands are currently prepared to address.
The other piece is scale. Closing that gap has traditionally meant more supplier conversations, more manual verification, more triangulation—none of which is auditable or repeatable at the volume brands actually operate at. You can’t have a one-to-one conversation with every supplier for every batch. In our conversations with brands, we are hearing they need ways to verify material reality that runs continuously, generates evidence automatically, and holds up to scrutiny without a human chasing paperwork.
On what verification looks like in practice: Rather than starting with certified materials and trusting the chain of custody to hold, start with verifiable physical proof and let certification and digital traceability data build on top of it. Certification tells you what was declared; physical verification confirms what’s actually there. The two work best together—and the companies preparing well are the ones adding that evidence layer now, so documentation becomes one strong input among several rather than the ceiling of what can be proven.
MeiLin Wan
Founder and CEO
GenuTrace
On the threat to business as usual: The industry is bracing for detentions and WROs [withhold release order] on specific known-risk regions. What it’s not preparing for is scrutiny of “compliant” supply chains that turn out to have laundering points nobody flagged. Blended lots, transshipment through third countries, and paper trails that look clean but don’t match the physical fiber are the real exposure. A supplier can be fully UFLPA-compliant on paper and still be sourcing commingled cotton that includes fiber from a restricted region.
CBP’s own Forced Labor Enforcement Operational Guidance, released the same week as the EO, spells this out for cotton and apparel specifically: importers need documentation tracing the supply chain from the bale level all the way to the finished product, with every entity in that chain identified. Not the finished garment. The bale. That’s a much deeper standard than most sourcing teams are working to today.
GenuTrace’s test for this has always been simple: if you claim it, can you prove it? Companies that build in that verification now, at the bale level, will have proof in hand before CBP asks. Companies that wait will be reconstructing chain of custody under a 90-day-or-less penalty clock.
On what verification looks like in practice: Think of it like a bank accepting a check. The check looks legitimate, it has a signature, an account number, an amount. But the bank still verifies funds before it clears, because paper alone was never proof of value. Origin documentation works the same way. A certificate of origin is the check. Forensic testing—such as isotope analysis—is the bank verifying the funds are actually there. Per the CBP report, the same guidance explicitly names isotopic testing as a tool it encourages importers to use to verify that claimed origin matches actual origin.
Shameek Ghosh
CEO and Co-Founder
TrusTrace
On what buyers need to ask suppliers today: EO 14411 puts U.S. Customs and Border Protection and Department of Homeland Security on a 45-to-180-day clock to rewrite the rules governing importers of record—and the direction is clear: tighter disclosure requirements, a 50% penalty floor and “good standing” tied directly to your ability to import at all.
Sourcing executives need to move from asking suppliers “can you certify this” to “can you show me this.” That means primary data on facility, product and material origin; not just supplier attestations or third-party risk scores that flag countries and categories rather than actual shipments. It also means asking upstream tiers directly about beneficial ownership and business affiliations, since that’s exactly what CBP will be scrutinizing under the new IOR [Importer of Record] rules.
The conversation should also cover speed. With faster seizure and disposal authority in the order, brands need suppliers who can produce documentation in days, not weeks, when a shipment is flagged.
On the threat to business as usual: The industry is bracing for the disruption everyone can name and under-preparing for the one nobody’s naming: data fragmentation across an expanding compliance stack. Brands are juggling CBP/UFLPA, CSRD, CSDDD, EUDR and DPP obligations, each with its own data model—and most are solving each one in a silo, multiplying cost exactly where regulators are starting to cross-reference each other.
Centralizing that data was the first problem the industry had to solve, and most serious players have now done it. The next challenge is what happens after centralization; a unified dataset still needs someone to manually interpret it and decide what’s urgent. Brands that figure out how to make their data actively surface risk, rather than just store it, will be the ones who see the next disruption coming instead of reacting to it.
Dr. Gediminas Mikutis
Chief Technology Officer
Haelixa
On what buyers need to ask suppliers today: Sourcing executives should be asking suppliers a more demanding question than “Do you have the documentation?” They need to ask: “Could we prove that this documentation relates to the actual goods being shipped?” Executive Order 14411 signals greater scrutiny of supply-chain disclosures, country-of-origin claims, transshipment, forced-labor exposure and inconsistencies between customs records. CBP has also made clear that importers, and not simply their overseas suppliers, are accountable for the accuracy of what is declared at the border.
We believe that paper records will remain essential, but sourcing teams should identify the points at which those records rely entirely on self-declaration. In higher-risk supply chains, physical traceability can independently connect the product to its documented journey, helping identify substitution or diversion before the shipment reaches the border.
On the threat to business as usual: The recent Transformers Foundation report beautifully summarized how the industry has invested heavily in supplier mapping, certifications and digital traceability platforms, but these systems largely record what participants declare. As materials are aggregated, blended and transformed, the connection between those records and the physical product can be weakened or lost. The next disruption may therefore come when a regulator, a journalist or a retailer asks whether the company can independently substantiate that claim for the specific shipment.
On what verification looks like in practice: Documentation, certifications and digital records remain essential, but they should be reinforced at the supply-chain points where substitution, commingling or identity loss is most likely. That means establishing identity as far upstream as possible, testing on a risk-based basis and connecting independent verification results to the digital record. The future of traceability is ensuring that digital data corresponds to the product in front of you.
