US enforcement of forced-labor rules is intensifying, and the EU’s Digital Product Passport mandate lands in 2027. Our founder leads every engagement, backed by a dedicated team that maps your exposure and hands you a structured plan — in weeks, not months.
If you source cotton apparel from Bangladesh, Vietnam, Pakistan, or anywhere with regional cotton-origin risk, US Customs can hold a shipment over an origin you cannot see from tier 1. The burden of proof sits with the importer — and a clean tier-2/tier-3 trail is the only thing that lifts it. A detained shipment costs in delays, storage, and legal time long before anything is resolved.
Every textile product sold in the EU will need a machine-readable Digital Product Passport under the ESPR mandate by 2027 — materials origin, recycled content, repairability, carbon. The data has to come from your suppliers and aggregate up to you. Most brands selling into Europe have not started, and the suppliers feeding the passport are not yet generating the data.
Most trade-compliance advisors are former officials or attorneys working from a template. We work from live infrastructure and real supply-chain data.
Provena Trust is deployed today, generating real product-passport and traceability data with manufacturers. We advise from what is actually in production — not from a concept.
We work with the manufacturers and the importers. A US-only advisor sees the importer’s paperwork; we can trace a shipment from cotton origin through spinning, fabric, and cut-and-sew to US port entry.
Every engagement is led by our founder and run by a dedicated team. Because our infrastructure does the data work that a consulting firm would bill out by the hour, a readiness audit takes two weeks — not a quarter.
Pricing is shared on a scoping call once we understand your supply chain.
For importers sourcing cotton apparel from Bangladesh, Vietnam, Pakistan, or other origin-risk regions.
We map your tier-2 and tier-3 supply-chain risk and produce a prioritized risk list and a Customs-dossier readiness package — the evidence trail you would need if a shipment were ever questioned. Two weeks.
Scope a UFLPA audit →For brands selling into the EU ahead of the 2027 ESPR deadline.
We map the passport data the mandate will require against the data you have today, identify the gaps, and hand you a remediation roadmap — including what your suppliers need to start capturing now.
Scope a DPP assessment →For importers whose sourcing leans on Bangladesh.
Bangladesh exits Least Developed Country status in November 2026, which reshapes preferential tariff treatment. We analyze what the change — alongside the 2026 US–Bangladesh trade terms — means for your landed cost, sourcing mix, and tariff eligibility.
Scope an LDC review →For importers who feel generally exposed but have not had a specific Customs event.
The broadest entry point: forced-labor readiness, CTPAT eligibility, country-of-origin documentation, and customs-audit risk in a single engagement, scoped to your situation.
Scope a gap assessment →How an audit is delivered depends on where your goods originate — and we are explicit about that up front.
In Bangladesh, our platform is already deployed with manufacturers, so we can work from origin-side data directly — supplier records, production data, and traceability captured at source.
For Vietnam, India, Pakistan, and other origins, we build the picture from your import and shipment records, public and commercial trade data, and our own tooling. We tell you where the certainty is strong and where it depends on supplier cooperation, rather than implying a visibility we do not have.
We are not a law firm, and we do not pretend to be one. We map your documentation against published enforcement criteria, find where the evidence trail breaks, and assemble the package your customs attorney and broker need to do their job well.
That line matters. A compliance program has three parts: the documentation, the legal interpretation, and the customs filing. We own the first and make the other two faster and cheaper — we do not issue legal opinions or represent you to the authorities. When an engagement turns into an active enforcement matter, we work alongside your counsel, not in place of them.
Every engagement is led by our founder, Zeeshan Khan, and run by a dedicated team. Zeeshan began his career on the founding team of Oracle’s ERP and Supply Chain Manufacturing Applications group, and spent the following decades inside the systems that move physical goods — consulting on the BAAN manufacturing ERP rollout with large US manufacturers through American Management Systems, then with major agricultural-technology distributors across Southeast Asia. That arc — three decades simplifying supply-chain complexity, well before “trust” became a compliance requirement — is why our advisory reads supply chains the way an enforcement officer does, and has tracked the forced-labor enforcement regime closely since it took effect in 2022.
A UFLPA Exposure Audit hands you a prioritized, line-by-line risk register — every component traced as far up the chain as the evidence allows, each with its documentation status and a clear next action. Below is an illustrative extract showing the structure. The data is fabricated; the format is real.
| Tier | Component | Stated origin | Documentation status | Risk | Recommended action |
|---|---|---|---|---|---|
| 1 | Cut & sew | Bangladesh | Complete — verified | Low | Retain on file |
| 2 | Fabric mill | Bangladesh | Complete — verified | Low | Retain on file |
| 3 | Yarn spinner | Bangladesh | Partial — mill cert only | Medium | Obtain cotton-origin affidavit |
| 4 | Raw cotton (lot A) | “Regional / mixed” | Missing — no origin trace | High | Trace lot; isolate at-risk supply |
| 2 | Trim & thread | China | Complete — verified | Low | Retain on file |
| 4 | Raw cotton (lot B) | US (verified) | Complete — gin record | Clear | Eligible for clean-cotton pathway |
The deliverable is the start, not the end. Once an engagement shows where the gaps are, most clients want help closing them — and keeping them closed.
That work runs on Provena Trust, the platform underneath our advisory practice: it issues the product passports, maps the audit frameworks your buyers require, and answers tariff and origin questions as they come up. Where a client needs ongoing visibility rather than a one-time fix, the platform becomes the system of record. We scope that step only after the first engagement has done its job — never before.
Tell us where you source and where you sell. We will tell you which engagement fits — or tell you honestly if you do not need one yet. The first call is with our founder, and there is no obligation.
Book a scoping call →