texfash: How much important has traceability become in the cotton sector? Most discussions seem to veer around Xinjiang cotton only. Is that the only focus area? But surely cotton everywhere should be important?
Michela Puddu: Regulations require companies to trace their supply chain back to the cotton bale to prove that products were not made with forced or child labour. The biggest driver by far is the Uyghur Forced Labor Prevention Act (UFLPA) in the US, which obliges companies wanting to import cotton to the US to provide evidence to the US Customs and Border Patrol (CBP) that those products were not made with forced labour.
When requested by CBP, importers need be able to trace the supply chain of the goods under review and demonstrate that imported goods were not produced or manufactured in Xinjiang. Enforcement of the UFLPA has resulted in high-profile scandals, product detentions, and induced brands to take traceability seriously. In March 2024, the EU agreed to adopt a regulation banning products made with forced labour. Therefore, brands have started to proactively ensure the traceability of cotton, rather than simply providing evidence when regulators request it or investigations (led by newspapers, NGOs) target their activities.
However, the interest in traceability extends beyond forced labour. Brands and retailers need traceability to support sustainability claims. This is required to comply with new anti-greenwashing and supply chain due diligence regulations (e.g., Corporate Sustainability Due Diligence Directive, Eco-design for Sustainable Products Regulation), but also to satisfy consumers, investors, and achieve corporate ESG targets.
Cotton traceability is not just because of labour issues. A few years ago there was a scandal involving the sale of falsely labelled Egyptian cotton products by Indian textile manufacturer Welspun to big US retailers. Is such a thing a concern now? What does your experience say?
Michela Puddu: Indeed, the issue is not only about product origin and related social practices. It also encompasses other environmental and social issues that can occur at any point in the supply chain: products can be substituted and mixed up, losing their integrity and sustainability credentials. The Egyptian cotton case is just one example. Standards have also faced challenges due to the lack of physical traceability of materials. Incidents involving mixing non-certified cotton with certified one, as well as incidents involving the use of fake certificates like for GOTS, the most renowned organic cotton standard, have occurred.
To address these issues, standards, brands, and organisations have been working together to find solutions to improve traceability in global supply chains. Enhanced solutions typically combine traditional documental traceability (e.g., transaction certificates) with new physical and digital technologies. Physical tracers (e.g., DNA tracers like Haelixa's technology, optical tracers) verify material claims, while digital solutions enable data safety, consolidation and sharing. Interestingly, standards are starting to consider introducing physical traceability to go beyond the mass balance method.
Another area where traceability is imperative is recycled cotton. Traceability is crucial to prove the recycled origin of the fibres, but it remains a grey area with little progress. I anticipate this becoming a pressing issue as recycling initiatives multiply and regulations (e.g., EPR) impose a company’s circular systems to stay in business.