By Ana Hinojosa, Oritain Advisor and Former CBP Executive Director
Regulations like the Uyghur Forced Labor Prevention Act (UFLPA) are not just passing trends – they are here to stay. With the focus on supply chain compliance getting tougher, U.S. Customs and Border Protection (CBP) and other governments are asking importers to take increased and additional responsibility for their supply chains.
What does this mean for you as an importer?
You cannot solely rely on neatly packaged documentation or written or verbal assurances anymore. You need tools that provide verifiable and objective scientific evidence.
It is important to note that CBP is already using these advanced tools to identify and assess the risk of non-compliance.
The agency has recently released guidance encouraging importers to integrate isotopic testing into their due diligence programs. As CBP explains, “Isotopic testing is a scientific method that identifies the atomic structure of naturally occurring materials, or a “fingerprint” of the material, affected by local environmental conditions. When that fingerprint is compared to a library of like materials from various geographic areas, the test can determine that the raw material is consistent with the claimed geographic origin.”
Isotopic testing reveals the truth in origin and can verify whether the raw materials you are importing are coming from where they say they are.
CBP recommends using the technology as a preventative measure that should be part of your compliance strategy from the start – not just a tool for troubleshooting or when detentions happen.
CBP is not just focused on cotton, they are looking across all industries. From the fashion industry perspective, many brands seem to think products made of synthetic fibers are a safer option but that’s a false assumption. Even if your product is 70% synthetic and only 30% cotton, the agency will ask where that cotton and synthetic fibers came from. They are looking at all products that could contain prohibited materials, regardless of percentages.
Whether it’s UFLPA or EU’s Corporate Sustainability Reporting Directive (CSRD) or deforestation laws – regulators want transparency and accountability, and they want it all the way down your supply chain. You must dig deep in your supply chain and ask tough questions, like:
Who are your suppliers working with?
Where are they sourcing their raw materials coming from?
Are there risks buried somewhere in the supply chain?
This is where isotopic testing becomes valuable. The innovative technology gives you the confidence to say, “Yes, this is exactly what I contracted for.”
It provides the objective scientific proof regulators are asking for.
It’s not just about cotton or synthetics anymore, it’s about having confidence and transparency into what’s happening in your supply chain.
CBP leverages isotopic testing to determine risk in suspect supply chains. Make sure your provider complies with the qualifications outlined by CBP’s guidelines.
