Transparent is not the same as traceable
In 2022, a brand selling organic cotton t-shirts discovered that some of its cotton may have come from Xinjiang - a region in northwest China that produces roughly 20% of the world's cotton supply, and the centre of well-documented reports of forced labour involving minority populations. Not because anyone had deliberately sourced it there. Because a supplier had bought from another supplier, who had bought from a trading house, and somewhere along that chain the declarations stopped matching reality.
The brand had a supplier list. It had audit certificates. It did not have a way to check whether the cotton in its products was what anyone had said it was.
That is not an unusual story. It is the normal condition of most fashion supply chains today.
Two words. One confusion.
Disclosure and verification are not the same thing. In much of the fashion industry, they have come to be treated as if they were.
Transparency means a brand is willing to share what it knows about its supply chain. Traceability means it can actually verify what is happening there. Most brands have some of the first. Very few have much of the second.
Transparency answers: what are you willing to tell us? Traceability answers: what can you actually prove?
Here is why the difference matters. Fashion brands do not manufacture anything themselves. They buy from suppliers, who source from other suppliers, who source from others still. At each step, information moves up the chain as declarations - documents stating that this cotton is organic, that this factory is certified, that this yarn came from a particular country. Brands typically publish those declarations in good faith. When a claim turns out to be wrong, it is usually not because anyone lied with intent. It is because no one had a reliable system to verify what they had been told.
A supply chain built on declarations looks identical from the outside whether those declarations are accurate or not.
How deep the gap goes
The 2023 Fashion Transparency Index makes the gap concrete. Of the 250 largest brands assessed, disclosure drops sharply as you move upstream:¹
Tier 1 (garment assembly) - 52% of major brands disclose
Tier 2 (fabric mills, dyeing, finishing) - 29% disclose
Tier 3 (yarn spinning, fibre processing) - 12% disclose
Tier 4 (farms, gin houses, raw material origin) - 8% disclose
In the index's dedicated Traceability section, 45% of brands scored between 0% and 1%.¹
That is not a map of a supply chain. It is a sketch of its top layer. The deeper tiers are not obscure footnotes - they are where the most significant risks sit, where labour conditions are hardest to monitor, and where the workers with the least power are most concentrated.
When audits confirm the wrong thing
The standard response to this problem has been third-party auditing. Send an inspector to a factory, check conditions against a standard, issue a certificate. Most major brands run audit programmes and many suppliers carry multiple certifications.
The limitation is structural. Audits assess a declared, known facility at a specific point in time. They do not verify where materials came from. They do not catch work that has been passed on to other facilities without the brand's knowledge - a practice more common than the industry tends to acknowledge.
A study published in Management Science analysed 32,000 orders across factories in Bangladesh, Cambodia, China, Indonesia, and Vietnam. It found that 36% of orders were subcontracted without brand authorization.² When that happens, the audit of the declared supplier tells you nothing about the facility where the work was actually done.
Ali Enterprises in Karachi was certified SA8000 compliant three weeks before a fire killed more than 260 workers. The auditors had visited. They had not found barred windows, locked exits, or an illegally constructed floor.³ Certification confirmed that a facility had been assessed. It said nothing about what was actually happening inside it.
The cotton from Xinjiang makes the same point at scale. After the US Uyghur Forced Labor Prevention Act took effect in June 2022, testing found that 19% of 822 cotton-containing products still contained Xinjiang cotton - including products from brands that had publicly stated they no longer sourced from the region. Of samples labeled as single-origin US cotton, 57% were not.⁴
The brands were transparent. They were not traceable.
Can traceability tools actually solve this? Honestly: partly.
This is where the conversation usually turns to technology. Physical tracers, DNA markers, isotopic analysis, blockchain tokens - these tools exist, they are being deployed, and they represent genuine progress. But they come with real limitations that tend to get lost in the excitement.
Physical tracers can be applied fraudulently. A luminescent pigment or a DNA marker added to cotton does not prove the cotton is what it claims to be. It proves the marker is present. If a marker is applied to the wrong material, or after the fact, the chain of custody it appears to represent is fictional.
Blockchain records what you tell it. The technology creates an immutable log - but only of the data entered into it. If a supplier inputs incorrect information at the start of the chain, every subsequent record confirms that incorrect information with perfect reliability. Garbage in, garbage out, with cryptographic certainty.
Isotopic testing has geographic limits. Cotton from different growing regions can share similar isotopic signatures, particularly where climatic and soil conditions overlap. Testing can narrow origin significantly - but it cannot always distinguish between neighbouring countries, and it cannot work backwards through extensive blending of fibres from multiple sources.
The cost is real. Comprehensive traceability infrastructure - tracers, digital platforms, independent verification - requires serious investment. Only an estimated 19% of fashion companies currently have full visibility over their supply chain.⁵ For mid-size brands without large compliance budgets, the gap between aspiration and implementation is significant.
None of this means the technology is useless. The most credible approaches combine physical markers with digital tracking and independent verification - each method compensating for the weaknesses of the others. Fashion for Good's assessment of 17 tracer companies concluded that physical and digital approaches work best together.⁵
Traceability is a foundation. It is not, by itself, an answer.
Where regulation is heading
The regulatory trajectory in the EU and UK is moving from disclosure toward evidence. Three instruments define the shift:
Ecodesign for Sustainable Products Regulation (ESPR) - mandates Digital Product Passports for textiles, with supply chain traceability requirements phasing in through 2033, from Tier 1 documentation through to complete verified chains from raw material to finished product.
EU Forced Labour Regulation - applicable from December 2027, requires clear evidence that products are free from forced labour. A public supplier list does not constitute that evidence.
Empowering Consumers Directive (ECGT) - enforceable from September 2026, limits generic environmental claims that cannot be substantiated. Calling something "responsibly sourced" will need to mean something specific and verifiable.
The direction is clear: verification, not just disclosure.
The honest picture
The deepest problem here is not technical - it is structural. A system built on declarations was never designed to be verified, and bolting traceability tools onto it afterwards only goes so far. The brands most likely to actually know what is happening in their supply chains are not the ones with the most sophisticated compliance software. They are the ones that chose their suppliers carefully to begin with - that built real relationships with producers already operating with integrity, visited the places their materials come from, and made visibility a condition of sourcing rather than an afterthought.
That is a different approach to the problem, and it is the premise behind t.issu & co: helping brands source from pre-qualified producers who are already doing things well, so that supply chain visibility starts at the origin rather than being retrofitted at the end.
The workers at the base of that system - the ones on no list, in no audit, visible to no tool - are not waiting for the technology to improve. They are working now, in conditions the current system was not built to see.
Key Sources
Fashion Transparency Index 2023 - Fashion Revolution
Unauthorized Subcontracting in Apparel Supply Chains - Caro, Lane & Saez de Tejada Cuenca, Management Science (2021)
Ali Enterprises case documentation - European Center for Constitutional and Human Rights
Nearly 20% of cotton products traced to Xinjiang - Fashion Dive (2023)
Assessing Tracer Technologies to Boost Traceability - Fashion for Good (2021)
