Closing Traceability Gaps with Origin Verification: Why Provenance Supports Stronger Risk Management
SJ StudioTue, September 8, 2026 at 6:00 PM GMT+3 6 min read
As supply chains have faced enhanced scrutiny in recent years, the fashion industry has responded with investments in traceability technology. Today, 87 percent of U.S. firms and 94 percent of UK companies have some kind of traceability system in place.
While traceability adoption continues to grow, the need for greater supply chain transparency remains critical. Analysis from Oritain's Market Insights Programme, which buys and analyzes around 1,000 garments per year, shows that the portion of brands with prohibited cotton rose from 64 percent to 90 percent between 2024 and 2025.
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Behind this backslide are traceability methods that leave gaps. Solutions like chain of custody tracking have their benefits, but relying solely on these traceability technologies is leaving companies exposed to risk. One key vulnerability is how the data in these platforms is compiled. Self-reporting and certificates can be false, leading to a "garbage in, garbage out" scenario that doesn't provide independent evidence of what is actually in a garment. "Despite traceability having scaled across the industry, verification hasn't really kept pace," said Gemma Lynch, chief customer officer at Oritain. "Risk is moving much faster than traditional compliance systems can adapt to."
In response to evolving regulatory requirements, including the Uyghur Forced Labor Prevention Act (UFLPA), and heightened expectations around supply chain transparency, many organizations have diversified sourcing and manufacturing footprints across different regions to try and distance themselves from risks. However, geographic shifts alone do not necessarily remove underlying supply chain risks. Raw materials and inputs often move through complex, interconnected global networks, meaning potential areas of concern can remain embedded further upstream.
Additionally, allocating more to certain locations can open companies to new risks: Factories facing an influx of orders might subcontract to overcome capacity strain, and these new vendors are often unknown or unvetted. "Risk isn't exclusive to one region or one commodity," said Lynch. "The more complex the supply chain is, the easier it is for prohibited or mis-declared material to enter without a brand necessarily knowing."
Companies whose goods were restricted under the Uyghur Forced Labor Prevention Act (UFLPA) may previously have redirected products to markets with fewer regulatory constraints, yet the rapid expansion of supply chain due diligence, forced labor and trade compliance requirements—including the EU Forced Labour Regulation and Corporate Sustainability Due Diligence Directive (CSDDD)—alongside heightened customs enforcement, Section 301 investigations and evolving tariff regimes, is reducing the viability of this approach and increasing the need for greater transparency, visibility and confidence across global supply chains.
"Provenance is becoming a license to operate. It's not enough to prepare for one border or one regulation; businesses need systems that can stand up to scrutiny across different jurisdictions, customers and regulators," said Lynch. "Compliance needs objective evidence, as opposed to a paper trail, to make sure that it stands up under scrutiny. That requires brands to shift from reactive compliance to a more proactive and programmatic approach to supply chain management."
Beyond mere compliance, companies' reputations are also at stake. For instance, deforestation concerns can hurt a company's standing with the public, and two-thirds of consumers in an Oritain survey said they don't want their purchases to be tied to deforestation. Being able to substantiate that the cattle used for leather come from ethical land management can therefore protect brand equity.
One method to get ahead of potential issues is instituting regular raw material analysis, creating consistent oversight on input origins. Oritain's forensic origin verification is built on a foundation of scientific data collected from sourcing regions around the world. Using naturally occurring characteristics found within materials, Oritain creates Origin Fingerprints that enable organizations to independently verify where products come from and demonstrate confidence in the integrity of their supply chains.
Oritain works with its members to build programmatic verification strategies tailored to their needs, taking into account factors such as production volumes, supply chain structure and sourcing risk. The Membership programme, launched in 2025, offers multiple tiers designed to support different levels of assurance, insight and control. Depending on where risk is greatest within the supply chain, testing can take place from yarn through to finished goods. By taking a programmatic approach, customers gain an ongoing view of supply chain integrity over time rather than relying on individual test results. If a potential issue is identified, they can work with suppliers to investigate and address the risk. As Lynch explained, "A programmatic approach gives multiple data points over time, which allows our customers to effectively manage risk rather than reacting to single data points."
Next Level Apparel has been working with Oritain for several years. The company—which specializes in premium blank apparel—adopted Oritain's forensic origin verification to supplement its existing visibility efforts, which include requiring each tier 1 supplier to disclose subcontractors and maintaining direct relationships with tier 2 fabric manufacturers. Between its own disclosure work and its partnership with Oritain and membership with the U.S. Cotton Trust Protocol, Next Level Apparel will have full visibility down to the farm level.
As a member of the Fair Labor Association, Next Level Apparel adheres to a code that includes monitoring for forced labor in its supply chain. Coupled with escalating traceability demands—particularly around EU regulations—the company looks to Oritain as an added lens into labor practices.
A Gold-level member, Next Level Apparel is consistently analyzing materials on a monthly basis, focusing on the fabric production process. This means regular, repeated checks, which keep vendors focused on compliance. The approach is to "trust, but verify" supplier claims. "We don't want our suppliers to get complacent and then maybe cut corners by sourcing from prohibited regions," said Marissa Garcia, director, responsible business at Next Level Apparel. "We want to send a very clear message that that's unacceptable."
Should anything surface as a risk, the company can now identify upstream players such as ginners and spinners, allowing it to correct issues more effectively with "concrete action." "As a smaller company, we can still do big things when it comes to understanding our supply chain," said Garcia.
Speaking about Next Level Apparel, Oritain's Lynch said, "They're a strong example of what it looks like when an organization treats origin verification as a long-term program rather than just a one-off compliance exercise…Verification can create real value when it's embedded into sourcing standards and customer confidence."
Much like Next Level Apparel's approach, which encompasses supplier engagement and disclosures alongside origin verification, Oritain suggests connecting its forensic scientific services with other tracking solutions—like digital chain of custody tracking—for the strongest line of defense. This enables them to back up claims and ensure the data is accurate. "The industry needs a layered model, with supplier engagement, chain of custody controls and documentation, risk assessments and then independent forensic origin verification," said Lynch. "All those layers provide the appropriate risk mitigation whereas just one of them alone won't stand up to scrutiny."
Click here to learn more about Oritain.
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