For US importers and brands

Your buyer asks how you know. Right now the answer takes three weeks.

Forced-labour duties on apparel took effect in July. The EU’s product passport lands around 2028. Both come down to one question about your supply chain — and most importers cannot answer it quickly, because the evidence is scattered across a hundred inboxes.

Our founder leads every engagement. You get a structured answer in weeks, not a quarter.

Book a scoping call Take the readiness drill
A question worth timing

A container is stopped on Tuesday morning. What can you put in front of Customs by Thursday?

Container held

Tue 09:00

Where the days go

The gap

Response due

Thu 17:00

Almost nobody in the mid-market has measured this. Most people assume days. When we run it as an exercise, the answer is usually weeks — and the reason is never the part they expect.

That gap is not really a compliance problem. It is a time problem wearing a compliance costume. Demurrage accrues daily, the delivery window closes, and the chargeback for a late delivery can cost more than the goods. The paperwork is what is slow; the money is what is lost.

We run that exercise with importers as a 40-minute session on one of their own products. It costs nothing and there is no pitch inside it.

What changed in July

Forced labour is now a duty, not just a detention risk.

On 2 June 2026 the US Trade Representative found that 60 economies had failed to prohibit or enforce against imports made with forced labour. After more than 1,600 written comments and three days of hearings in July, the action was made final. Additional duties apply to goods entered for consumption on or after 24 July 2026 — 10 per cent for some economies, 12.5 per cent for the rest.

This is a different kind of exposure from a detention. It attaches to where you source, not to anything your supplier did. It is on every entry, not on the ones that get stopped.

There is also a textile mechanism that would let a volume of apparel and textile imports enter at a reduced rate, tied to US textile exports. The quota administration was not ready at the time of the action and was expected to become workable from around September. If you import apparel, this is the part to watch.

Read USTR’s notice →
The passport wave — EU sales

The data has to come from your suppliers.

Textile products sold in the EU will need a machine-readable Digital Product Passport under the Ecodesign regulation — materials origin, recycled content, repairability, carbon. The delegated acts that set the detail are still in progress, and the realistic date for textiles is around 2028 rather than 2027.

That is not a reason to wait. The data has to come from your suppliers and aggregate up to you, and the suppliers feeding the passport are not generating it yet. The lead time is in the supplier onboarding, not in the software.

Both pressures ask your buyer’s question back at you: how do you know?

Read the thesis →

For US importers and brands

What this looks like in practice.

What you have now

Three hundred supplier names in a spreadsheet, checked by eye, once, by someone who had four other jobs that week.

What goes wrong

The same factory is written three different ways in your own file, and none of them matches how it appears on the government list. The list has moved since you looked. And when somebody asks how you checked, there is nothing dated to show them.

What we hand you

A dated record of exactly what we searched and what we found. A short list of suppliers we could not resolve, each with the question to send that supplier, written and ready to forward. And a re-check when the list moves.

How an engagement runs

Measure it, build it, keep it current.

Drill

We measure the gap on one of your own products.

Nine questions, timed. At the end you have a number about your own operation that you did not have before — and a list of exactly which links in the chain are slow. Paid, and credited in full against a build.

40 minutes · fee credited
Build

We build the system that closes it.

Your own supplier registry with honest tier depth, document capture and extraction, a gap register that shows unknowns as unknowns, and dossier assembly in the shape the request arrives in. It runs against your systems and your data.

Scoped per engagement
Run

It stays current instead of decaying between audits.

Documents refreshed on a cadence, new suppliers absorbed, the register maintained, and a re-check when the government lists move.

Ongoing

How we work, in detail →

Where engagements start

Fixed-scope engagements, each built to answer one question.

Most importers start with the drill. If you already know which question you need answered, these are the scoped entry points. Pricing is shared on a scoping call once we understand your supply chain.

UFLPA Exposure Audit

For importers sourcing cotton apparel from origin-risk regions.

We map your tier-2 and tier-3 supply-chain risk and produce a prioritised risk list and a Customs-dossier readiness package — the evidence trail you would need if a shipment were ever questioned.

Scope a UFLPA audit →

EU DPP Readiness Assessment

For brands selling into the EU ahead of the requirements expected around 2028.

We map the passport data the regulation 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 →
What you actually get

A register that shows the gaps, not a score that hides them.

Every component traced as far up the chain as the evidence allows, each with its documentation status and a clear next action. An unknown is never rendered as a pass.

Tier Component Stated origin Documentation Next action
1 Cut & sew Bangladesh on file Retain on file
2 Fabric mill Bangladesh on file Retain on file
3 Yarn spinner Bangladesh partial Obtain cotton-origin affidavit
4 Raw cotton (lot A) “Regional / mixed” absent Trace lot; isolate at-risk supply
2 Trim & thread China on file Retain on file
4 Raw cotton (lot B) US gin record on file Eligible for clean-cotton pathway

Illustrative example — fabricated data, not a real client

The unresolved list

Alongside the register you get the suppliers we could not trace, each with the exact message to send that supplier, written and ready to forward. Most clients send them the same afternoon.

Limits

What this is not.

We are not a law firm and we do not give legal advice. We assemble the documentation; counsel handles the legal response.

We are not a screening database. We do not tell you which suppliers look risky — we tell you what you can and cannot evidence about the ones you have.

We cannot guarantee any outcome with Customs, and no one who tells you otherwise should be believed.

We cannot produce evidence that does not exist. Where the record is missing, the system says so.

If your programme is smaller than a build. Not everyone needs a system. If you have a short supplier list and a document problem rather than a data problem, we can collect and organise the documents for you without building anything. Say so on the call and we will point you there.

Working on one of these problems?

If a piece here maps to something you’re facing — a held shipment, an LDC cost model, a passport mandate — that is exactly what our importer practice exists for.

See how we work