The TrusTrace Traceability Roadmap

is a practical guide to implementing

traceability in your company’s supply

chain. Aligning theory with real-life

case studies, interviews and useful

tools to support your journey, the

Roadmap is a holistic guide to

implementing traceability from

ideation to rollout and beyond.

1
Contributors

Author
Megan is a Sustainable Fashion Journalist and
Content Editor at TrusTrace, whose byline appears
Megan Doyle

in Harper’s Bazaar, the Business of Fashion,

Sustainable Fashion
Refinery29, EcoCult and others, covering fashion
Journalist tech, garment worker rights, traceability &
transparency, material innovation and more.

Managing Editor
Heading up marketing and educational efforts, Anja
is the driving force behind TrusTrace's efforts to
share insights and facilitate data-based
Anja Sadock

collaboration in the industry. Anja is the managing

Head of Marketing

editor of 'The Traceability Playbook' and ‘The

at TrusTrace
Traceability Roadmap’, as well as 'The Knowledge
Hub' - a platform for key legislation and traceability
insights.

Case Studies and Interviews

Baptiste

Carriere-Pradal
As chair of Policy Hub and Co-founder of 2BPolicy,
Chair of Policy Hub
Baptiste is helping to unite the apparel and footwear
and co-founder of industry to speak in one voice and propose policies
2BPolicy that accelerate circular and sustainable practices.

Cecilia
Cecilia leads the Maritime Anti-Corruption Network,
Müller Torbrand
a global business network working toward the vision
Chief Executive Officer of a maritime industry free of corruption that enables
of the Maritime
fair trade to the benefit of society at large. She is an
Anti-Corruption Network experienced anti-corruption expert with 15 years of
expertise in the compliance field.

2
 As an Innovation Analyst at ashion for Good s
F ’

J a e Crowle
m s y
Innovation Platform, ames focuses on
J

Innovation Analyst at
transparency and traceability initiatives, innovation,
F ashion for Good and implementation for brands and associated
partners.

Karolin is a Product Specialist at GS1 standards,

creating the opportunity for companies of all sizes to
Karolin Catela

identify, capture and share unique information,

Product Specialist at

across the entire supply chain. Karolin is a specialist

GS1 Sweden
in traceability with years of experience in
standardization, development and implementation
across industries and in different companies.

Kit is Vice President at the research and data

analytics firm, Kharon. He helps lead global
Kit Conklin
business development and advises clients on the
Vice President of Kharon use of data to augment and scale sustainability,
traceability, and geopolitical risk management
programs.

Matthew Xu, a corporate compliance and

sustainability expert with 20+ years of experience, is
Matthew Xu
currently leading CSR & Sustainability in ASICS
CSR and Sustainability North America. He has developed ESG strategies,
Lead at ASICS implemented ethical sourcing and vendor
management programs, and provided sustainable
solutions for major global companies.

Natalie Grillon is Executive Director of Open Supply

Hub, an accessible, collaborative, supply chain
Natalie Grillon
mapping platform, used by stakeholders across
Executive Director of
sectors and supply chains. Championing access to
Open Supply Hub open data and transparent practices, Natalie has
worked for a decade to launch innovative solutions
to complex problems in global supply chains.

Sherr a ay F z l

Sherry is the Senior Manager of Global ESG &

Senior Manager, Global Sustainability Solutions at apestry. She has over
T

ESG & Sustainability 20 years of experience in Information echnology &

T

Solutions at apestry
T
Integrated usiness Processes and is establishing
B

the digital core for a multi brand operating model.

-

3
Advisors
As the co-founder and CTO of TrusTrace, Madhav
oversees the Product, Engineering and
Madhava Venkatesh
Sustainability/Innovation teams and sets the product
Co-founder & Chief and technology vision for the company. Madhava
Technology Officer at has been building solutions for 22+ years in cutting-
TrusTrace edge technology areas like Cloud & IoT, is a
member of the Forbes Technology Council.

As the co-founder and COO of TrusTrace, Sarva

leads the business operations and has extensive
Saravanan Parisutham
experience in leveraging technology to solve
Co-founder and Chief complex challenges. He has overseen numerous
Operating Officer at enterprise-scale traceability implementations,
TrusTrace helping brands achieve their business and
traceability goals successfully.

Special Thanks To
Jenny Wärn, Jo Johnston, Jocelyn Chan, Krister Gangfløt, Ramanathan Venkataraman, Santosh
Mohanram and Shameek Ghosh.

About TrusTrace
About Fashion for Good

TrusTrace was founded in 2016, with the objective
to fundamentally change the way fashion is
produced and consumed, after the four founders
witnessed the detrimental effects of pollution of the
local rivers, soil and air coming from unregulated
Fashion for Good is the global platform for
innovation. Fashion for Good unites the entire
fashion ecosystem, from brands, manufacturers and
suppliers, to consumers, to collaborate and drive the
change towards a circular industry.

dying factories and textile manufacturers in their

local community in Coimbatore, India. 

At the core of Fashion for Good is its Global

TrusTrace offers a market-leading platform for
supply chain traceability and compliance, that
empowers brands to know, prove and improve the
impact of their supply chain. The validated data
collected through the platform can be used for risk
management, compliance, product claims, footprint
calculations, the ability to confidently and easily
share data about product origin and impact, and
much more.
implementation.
Innovation Programme. The Innovation Programme
supports disruptive innovators on their journey to
scale, providing hands-on project management,
access to funding and a robust ecosystem of
mentors and experts. Fashion for Good also initiates
Foundational Projects, consortium projects that
bring innovators, brands, manufacturers and
funders together to validate technologies and
processes, to accelerate supply chain
4
TABLE OF CONTENTS
INTRODUCTION 6
DEFINING YOUR NEEDS 9
Defining Goals, Objectives and Outcomes 11
Industry Drivers 12
Key Considerations 14
Case Study: How Tapestry Defined its Goals 16
NAVIGATING LEGISLATION AND COMPLIANCE NEEDS 17
Three Categories of Legislation 18
Gathering Data for Compliance 19
Interview: Impact and Future of the UFLPA 21
Interview: Anticipating and Preparing for Incoming Laws 24
ENSURING YOUR ORGANIZATION IS ALIGNED AND READY 27
Internal and External alignment 28
Assess Your Readiness 29
Sourcing Models 30
Key Considerations 32
Case Study: Launching the ASICS Traceability Transformation 34
Case Study: How Tapestry Ensured Organizational Readiness 36
Find the Right Solution for Your Needs by Fashion For Good 37
The Traceability Innovation Landscape 39
Case Study: How Tapestry Found the Right Solution for Its Needs 43
How to make your implementation successful 44
Timeline and Planning 45
Prepare for Program Rollout 46
Project Team, Roles and Responsibilities 48
Key Considerations 50
Case Study: How Tapestry Launched a Successful Pilot Program 52
WHAT HAPPENS NEXT 53
Interview: Standardizing Traceability Industry-Wide 55
Interview: Taking Cues from the Maritime Anti-Corruption Network 57
Interview: Envisioning Fashion’s Traceable Future 59
A CALL TO ACTION 61
TOOLKIT 63
How to Calculate Return on Investment 65
Define Your Vision, Goals and Milestones for Traceability 68
Define Your Team and Establish Roles & Responsibilities 69
Define Your Program Roadmap for Implementation 70
GLOSSARY 71
INTRODUCTION

6
INTRODUCTION
Shameek Ghosh
CEO and Co-founder
importance, there is still not enough
TrusTrace
In just a few short years, supply chain
traceability has been recognized as the
central tenet of the fashion industry’s
sustainability transformation. Despite a
widespread understanding of its
importance, both to achieve internal
sustainability commitments and comply
with legislation, there is still not enough
established knowledge on exactly how to
achieve traceability.
actually achieve it? Our ambition with the
There is no sustainability without
traceability. Regardless of whether brands
want to avoid greenwashing, communicate
product information with consumers,
adhere to labeling criteria, or abide by
increasingly robust regulations, all of this
can only be achieved by identifying and
tracing a complex network of suppliers and
manufacturers.
methodology can be a useful reference for
In TrusTrace’s first Traceability Playbook,
released in June 2022, we outlined the
business case for implementing traceability
and the wider considerations for brands —
including incoming regulation, material
innovation, and the circular economy.
Despite a widespread understanding of its
established knowledge on exactly how to
achieve traceability.
“
The first playbook established the Three
Levels of Traceability — Supplier Mapping,
Product Traceability and Material
Traceability — and detailed how to achieve
these vital rungs on a ladder towards total
supply chain visibility.
As the why of traceability has become
clear, the next question is how do you
Traceability Roadmap is to help you
understand and achieve this. We have
expanded on the foundational knowledge
from the previous book with a practical
guide to every stage of the traceability
journey.
While the examples in this book are from
the apparel & footwear industry, the
other industries that share similarly
complex and high-impact supply chains. 
The fact is, there is no easy or immediate
solution to establishing robust traceability.
Each supply chain and each business is
unique, so the right solution depends on a
range of factors — from the size of
7
your business and goals you want to The Traceability Roadmap is broken into
achieve to the maturity of your processes distinct sections: the theory, key
and the product categories you operate in.

considerations, secrets to success, case

To give a comprehensive overview of the
traceability and sustainability solutions on
the market, we have collaborated with the
sustainability accelerator Fashion for Good,
studies to help you understand how brands
have applied the theory to their own
traceability journey, plus interviews with
experts, and a toolkit with downloadable
templates that you can use to get started. 

who were also part of the first playbook. 

We have collaborated with sportswear

One thing is for sure — capturing,
analyzing and building strategies based on
primary data is essential, no matter the size
of your business. So many of fashion’s
ESG commitments thus far have been
founded on generalizations and secondary
brand ASICS and Tapestry, owner of
Coach, Kate Spade, Stuart Weitzman and
newly launched Coachtopia, on a series of
real-life case studies explaining how these
groups established their own traceability
programs with the support of TrusTrace.

data points that are outdated, vague or

downright incorrect.

In this Roadmap, we will cover how to

define your business's traceability needs,
It’s no wonder that fashion has made little ensure your readiness for traceability, find
progress in reducing overall emissions.

the right solution provider, and guarantee a

successful implementation. In the final
Across the industry, everyone from the C- chapter, we discuss the importance of
suite to sustainability, legal, production and continuous development post-
sourcing teams are facing unprecedented implementation to ensure the return on
challenges and demands in this arena. your traceability investment.
Everyone has an important role to play in
ensuring that traceability not only gives you
data, but enables you to create impact. We
are here to support you by sharing the best
practice for supply chain traceability, based
on our years of experience in implementing
global traceability programs.  

The Traceability Roadmap is here to

educate, support, and guide you on your
journey. It is divided into sections that
mirror the journey a typical company will go
through when initiating and implementing a
traceability program. 

8
DEFINING
YOUR NEEDS

OUTCOME OF THIS CHAPTER

This chapter will give you a clear

understanding of business needs
across functions that drive traceability,
as well as the key challenges in
achieving those needs. It will help you
to identify your goals, outcomes,
success indicators, and prepare you to
calculate to return on investment to
ensure buy-in from your stakeholders.
9
DEFINING YOUR NEEDS

With no one size fits all traceability solution, To gain the support of decision-makers in

it’s crucial that each company rigorously your company, it’s important to present the

investigates and defines its needs when business case for a traceability platform.

developing a traceability strategy. At The selling points go far beyond achieving

TrusTrace, we have seen many companies compliance or ESG commitments — the

get stuck in analysis paralysis — unable to data acquired through a traceability system

move forward with a clear strategy because can help to make your company more

they’re thinking too long-term. 

efficient too.

In an ever-changing traceability landscape, So, how should you approach your

it’s important not get distracted by the traceability strategy? By investing in

uncertainty of what’s to come. Legislation, traceability solution providers that you trust

a tumultuous economy and unforeseen to help you reach your short-, medium- and

global events continue to shift the priorities long-term goals.

and actions of the industry, and it is

impossible to have perfect knowledge To define these, think beyond current

when you set out to implement traceability.

legislative requirements and create a more

holistic strategy that will make your

When building a plan without knowing the businesses robust and future-proof.

exact challenges you might face along the

way, it’s critical to strike the right balance

between developing a long-term vision and

ensuring you get started. 

10
Defining Goals, Objectives
and Outcomes
Without establishing your goals, objectives
and desired outcomes, a traceability
program is sure to derail and will fail to
create a meaningful impact. Before
starting, define the following: 
% To make accurate product claims
What are your goals?
% To confidently communicate
The business drivers pushing your
organization towards a traceability
solution. These could includee
% To comply with regulations like the
European Commission’s Green Claims
Directive, the Uyghur Forced Labor
Prevention Act (UFLPA), and the
German Supply Chain Act to secure
presence in key market
% To sell your products through retailers
with stringent sustainability policies
% To attract conscious consumers with
evidence-based claims about your
products
% To increase stock price or attract
sustainability investments like green
bond
% To make meaningful impact in your
supply chains to reduce carbon
emissions, improve biodiversity, and
enable social changes
collectio!
What are your objectives? 
The specific objectives you want to achieve
in order to reach your goals. These could
include:
% To ensure your products and supply
chain comply with regulations in all the
regions you sell i!
through the correct sustainability labels
sustainability credentials to consumers
without greenwashin)
% To audit your supply chain for fair labor
conditions or assess its environmental
footprint in order to identify how to
improve
What are your desired outcomes?
The measurable benefits that will signal the
success of this initiative. These could
include:
% To ensure all sustainability claims are
backed up by robust dat
% To automate the labeling of products
sold through online retailer
% To ensure the availability of all
information for regulatory compliance in
one single location
% To communicate with your suppliers on
a common platform and manage data
% To improve the accuracy of your data
and reduce the workload for you and
your suppliers
11
Industry Drivert
fn Compliance with Legislation 
sustainable materials need to be able to
Legislation is a driving factor in the
industry’s push to implement traceability.
The spectrum of laws and regulations that
are linked to traceability is broad (and
continuously expanding) which makes it
difficult to know exactly what data your
business should be collecting and how.
data on the volume of products
The laws that apply to your business will
depend on the regions you manufacture
and sell in, the requirements of third-party
retailers you stock products with, and the
scale of your operations. For more
information and to hear from policy experts,
read the next chapter called Navigating
Legislation and Compliance Risksx
>n Meet Sustainability Commitments
3 Decreasing emissions Companies
Many companies have made public ESG
commitments to reduce the environmental
and human impact of their operations. To
achieve these goals, a traceability solution
is necessary. Some commitments includeU
3 Moving to sustainable materials
Companies that plan to increase the
overall percentage of recycled, natural
or preferred materials in their product
offering need to know who is supplying
their materials. If a company wants to
move from virgin to recycled polyester
or conventional to organic cotton, it
needs proof that the materials are
indeed certified recycled or organic.
Companies keen to support their
suppliers through this transition to more
identify and collaborate with them.
3 Circularity Companies committed to
implementing repairs, recycling or
resale schemes should collect data on
the products and materials received
back into their ecosystem. This includes
recycled, repairs completed and resale
figures. Collecting this information will
help companies understand the impact
of circularity initiatives, and narrow their
focus to the most effective scheme. By
gathering data on repairs, for example,
companies can make informed design
and production decisions for more
durable products.+
that have overall emission reduction
plans in line with science-based targets
require a traceability solution to know
where the most impact is being made in
their supply chain. Analysing data
collected through a traceability system
is the only way to build an effective,
targeted emissions reduction strategy.
+
3 Social impact Companies that are
committed to respecting human rights
should ensure that they work with
facilities promoting fair and safe working
conditions. Analyzing data on social
practices and impact is key to achieve
this.
12
- Increase Business Efficiencies 

A traceability solution will provide you withN

There is a strong business case for i Quick access to data You can collect

collecting, analyzing and acting on primary all data points in one unified traceability

data. With primary data, you can have real system with easy access to information

time visibility of material movement across about your supply chain and products.

the supply chain, and can leverage this When all your data is structured in a

information to achieve business single location, activities like sharing

efficiencies.

data on product credentials (with

evidence) for retail partners, country of

A traceability solution gives you access to origin data for customs agents and

data that can not only improve your Corporate Social Responsibility (CSR)

understanding of the environmental and reporting on supply chain compliance is

social impact of your business, but also streamlined and simplified.]

enables you to weed out inefficiencies,

unwanted costs and waste. It paves the i Audits Companies are able to easily

way for a more dynamic, efficient and track the behaviour of their suppliers for

strategic business.
auditing purposes when data is

recorded in an accessible format. A

traceability solution allows you to see in

real-time the movement of goods

through their supply chains and keep on

top of compliance. This also means

any changes that happen to your

products in the production phase can be

identified and recordede

i The ability to optimize your supply

chain Companies that gather data and

intelligence around their supply chains

can react to external events with greater

agility. By understanding suppliers in

more detail, like what they provide, their

supply chain network, and how they

operate, companies can identify

alternative supply chains or weed out

inefficiencies based on the business

requirements. This can reduce costs,

time to market, and overproduction. 

13
Key Considerations

3 Balancing the short- and long-term

Consider the value of short-term and
There are a few key aspects to defining long-term goals. Starting with imminent
your needs when choosing a traceability laws will help tackle your immediate
solution provider. These considerations can risks, but don’t disregard the inevitable
help you win the support of key decision- rise of more robust, wide-sweeping
makers in your business by identifying the legislation around the world. To stay on
business value of traceability top of incoming laws and future-proof
your business, it will pay off to be
3 Risk vs. reward Consider the upfront ambitious, committed, and forward-
cost vs potential losses for thinking.
noncompliance or disintegration of
consumer trust. Buying a traceability
solution requires financial investment in
systems and teams, but the
inconvenience, reputational risk, cost
and delays caused by failing to comply
with laws like the UFLPA or being sued
by disgruntled customers are far
greater.
3 The value of primary data Whether
you want to do an LCA, comply with
regulations or improve your social
impact, just having an overview of your
supply chain is not enough. You need to
know exactly what goes on in it. Having
a robust, real-time view of the flow of
materials and goods enables you to
proactively optimize your operations
while building a resilient and fair supply
chain. Primary data can help you make
decisions that will transform your
business for the better.

In the Toolkit:

You'll find the Outline of Traceability

template to help you define your
vision, objectives, key milestones
and KPIs, as well as how to calculate
ROI based on your key focus areas.
14
THREE SECRETS TO SUCCESS
1.
Involve key stakeholders early on: ensure you capture all
potential needs and understand the interdependencies of
different goals before you start prioritizing them. Consider how
your traceability needs align with the wider business goals.

2.
Be crystal clear: define the value
and outcome you want to achieve
and set specific targets against
these. This makes it easier to align
internally, measure progress and
perform corrective actions.

3.
Get started: given the nascent nature of traceability, as well as the current and
upcoming laws governing this space, it will be impossible to get everything right
from the beginning. The key is to get started with the highest short-term priority,
still keeping long-term objectives in mind, and correcting your course as you
move forward.

15
Case Study:

How Tapestry Defined its Goals

It wasn’t about perfection; it was about

Sherry Fazal
having a general idea of our business
Sr Manager, Global ESG
needs, our customer expectations and the
& Sustainability
ESG story we want to tell about our
Solutions at Tapestry
company.

“
Tapestry’s strategic pillars for ESG are Our it was about having a general idea of our

People, Our Community and Our Planet. business needs, our customer expectations

Our work on sustainability is robust and our and the ESG story we want to tell about our

goals are significant: one of our most company. Our first step was to create a

critical goals is to achieve 95% traceability high-level roadmap that was going to guide

and mapping of raw materials to ensure a us as we built the systems but could be

transparent and responsible supply chain flexible when we needed to pivot or adjust.

by 2025. When we initially set the goal, it FY21 was a foundational year.

was about working backwards from there

— we knew that if we needed to trace our We knew the power of small wins, so we

materials, we needed to map our supply started with those and built on the

chain. 

momentum, which gave us the confidence

to tackle bigger challenges. For example,

One key learning was that it’s not just one of our commitments is to ensure 90%

about connecting tier one suppliers, tier two of leather is sourced from Gold and Silver-

suppliers and beyond, but having rated tanneries. We partnered with

substantial data sets and ensuring data reputable leather suppliers to ensure

integrity. We focused on cleansing the data tanneries were up to standard.

in our supply chain before we even tried to

connect the people. A company’s If they weren't, we wanted to help get them

traceability reporting is only as good as the there, not walk away from the vendor.

accuracy of its data.

That’s a really important part of Tapestry’s

work - we recognize we’re all on a journey

Early 2020 was the start of us having an together and it’s about making real

integrated systems architecture to support sustainable progress.

Tapestry’s sustainability journey. We knew

we needed systems and had to start

somewhere. It wasn’t about perfection;

16
NAVIGATING LEGISLATION
AND COMPLIANCE RISKS

OUTCOME OF THIS CHAPTER

This chapter will draw a bigger picture of

the legislative landscape today and in the
future, with the help of experts Kit Conklin
from Kharon, and Baptiste Carriere-Pradal
from Policy Hub. This chapter will help
you understand the key categories of
laws affecting apparel and footwear and
the data needed to comply with each of
these. Equipped with this knowledge, you
can align your broader organization,
which is covered in the next chapter.

17
NAVIGATE LEGISLATION AND COMPLIANCE RISKS
There are three main categories of
legislation to be aware of and develop your
data collection strategy around: due
diligence, claims & labeling and
sustainability reporting. Not all regulations
fit neatly into one bucket. Some, like the
EU Ecodesign for Sustainable Products
Regulation Proposal, will cover aspects
from several categories.  
An example is the French Anti-Waste for a
Due diligence includes laws that require
companies to identify and mitigate
environmental and/or social risks along
their supply chain. Laws on forced labor
require data on a product shipment level to
prove that goods have no forced labor in
any part of their supply chain, requiring the
collection of country-of-origin
documentation. Deforestation regulations
can require specific locations of individual
farms.  
report on targets and progress towards
Due diligence laws will also help you
achieve social impact goals, such as
implementing living wages or safer working
conditions. A code of conduct is not robust
enough to achieve social impact goals. To
achieve living wages in their supply chains,
companies must have visibility of suppliers,
access to information about the wages of
their employees, and a collaborative
relationship with factories to implement
wage increases.
also use this data to get a granular
Claims and Labeling laws require
companies to substantiate any
environmental or social claims made with
reliable and relevant evidence.
Requirements can range from top-line data
to highly granular information around the
product life-cycle, such as environmental
scoring, circularity, traceability, and other
sustainability information.
Circular Economy Law (AGEC), which
relates to the claims and labeling of
materials on consumer-facing labels.
AGEC requires companies to make
weight-based declarations of recycled
material content and disclose the
traceability of main materials by showing
countries of origin. 
Sustainability Reporting laws standardize
requirements for reporting, such as how to
Scope 1, 2, and 3 emissions reduction,
both in absolute and relative terms, as well
as for the total company and per product.
As many laws are still at the proposal
stage, the exact requirements are not yet
defined. Leading companies have already
started collecting and analyzing granular
data per shipment, so they are ready when
laws come into force. Beyond what is
required by compliance, companies can
understanding of their supply chain to
accelerate positive social, environmental
and business impact.
18
Gathering Data for

Compliance

By now, fashion companies are well aware

that they need data to comply with

regulations. But identifying what data they

need to gather is the most important piece

in the puzzle.

In the table on the next page, we have

called out the data requirements for six

major laws facing fashion businesses.

Having the data to hand will be central for

compliance with other laws and

regulations, as many have overlapping

data requirements.  

In the following chapters we’ll speak to two

industry experts, Kit Conklin from Kharon

and Baptiste Carriere-Pradal from Policy

Hub and 2BPolicy on how these laws are

impacting fashion businesses across the

world.

For a more extensive view on laws &

regulations, please visit the

TrusTrace Knowledge Hub. 

19
Category Example laws Data needed

Due Diligence US: The Uyghur Forced Labor Per purchase order and shipment:
Prevention Act (UFLPA)

Supply chain map, country of origin

of all suppliers, payment, production
EU: Ban on Forced Labor and transportation documentation.

Claims and EU: Corporate Sustainability Same as above including supply

Labeling Due Diligence Directive chain information, due diligence
Proposal (CSDDD) policies and measures to effectively
monitor, manage and mitigate risks,
to publish annual due diligence
strategies and statements.

FR: The French Anti-Waste for Geographical traceability of the 3

a Circular Economy Law major manufacturing steps
(AGEC) (weaving, dyeing, assembly/
finishing).

Amount of recycled material, and

recyclability of the product.

The presence of hazardous

chemicals, and microfibers if >50%.

Sustainability EU: Corporate Sustainability Environmental and social impact of

Reporting Reporting Directive Proposal the supply chain, including Scope 3
(CSRDP) emissions and wages

US: SEC Proposal for Climate- Same as the EU CSRDP as well as

Related Disclosure Rules carbon emissions

Cross- EU: Ecodesign for Sustainable Performance requirements on

category Products (ESPR) - Including durability, reparability, circularity,
Digital Product Passport (DPP). waste, pollution, carbon footprint,
harmful substances, destruction of
unsold goods, and more.

The DPP requires relevant

information about the full lifecycle of
the product, for easy consumer
access to decentralized information.

20
Interview:
The Impact and Future of the UFLPA
Kit Conklin
Traceability takes time to do right, and it
Vice President of
Kharon
As of June 2023, the Uyghur Forced Labor
Protection Act (UFLPA) has been in effect
for a year. This rollout of this unique,
precedent-setting law has put the fashion
industry on notice: take the rising tide of
regulation seriously or face financial and
reputational risks. The UFLPA has helped
to catalyze the adoption of traceability
solutions for compliance, but its impact on
global trade and geopolitical relations is far
more significant. 
impact that the UFLPA has had since it
To understand exactly how the UFLPA has
and will continue to impact apparel and
other imports into the United States, we
sought the expertize of Kit Conklin, Senior
Fellow at the Atlantic Council and Vice
President at the research and data
analytics firm, Kharon. 
been passed globally targeting this type of
Conklin helps lead global business
development and advises clients on the
use of data to augment and scale
sustainability, traceability, and geopolitical
risk management programs. He has
worked on China issues for over 15 years
and has testified in front of Congress on
the UFLPA.
visit the TrusTrace Knowledge Hub.
takes time to do it well, so brands should
be thinking about this before laws are
enforced.
“
Conklin shares his knowledge on the best-
practice approach to complying with the
UFLPA, how it compares to similar laws
internationally, how the law will evolve in
the coming year, and whether it is
effectively eradicating forced labor from
fashion’s supply chains. 
TrusTrace:
Kit, can you tell us a little about the
came into effect
in June 2022?
Kit Conklin:
The UFLPA took a lot of the sustainability
world by surprise because it’s the most
complex piece of legislation that has ever
issue. We have seen a huge uptick in the
number of shipments that have been
detained by CBP via their new UFLPA
authorities — the U.S. Customs and Border
Protection (CBP) has detained hundreds of
apparel shipments so far.
For an extended version of this interview,
21
The CBP explicitly stated that cotton would
be prioritized for enforcement, but what
we’re starting to see now is other
commodities being detained as well. This
includes things like polyester, leather
products, and a broader expansion of
detentions targeting goods made with
forced labor outside of Xinjiang.
Some in the industry have continued to
believe that the UFLPA only focuses on
Xinjiang cotton, but the law is infinitely
more complex and broad. It allows the
authorities to target shipments across
every industry and, sometimes,
enforcement has nothing to do with the
inputs themselves but rather the
companies involved with the manufacturing
process.
have learnt to crawl with cotton, but now
I recently had a conversation with a chief
sustainability officer for one of the world’s
largest brands and he raised an interesting
point that I don’t think many in the industry
are thinking about: commodities that aren’t
fabrics. Things like metals in shoes, for
example. A lot of times the due diligence on
those smaller commodities may not be the
same as the traceability work that’s being
done for cotton. If you have inputs in your
shoes that are metals made with forced
labor, the CBP has the authority to detain
that product, even if everything else in the
shoe may not be made in Xinjiang.
the UK, Europe and beyond, including
Companies are often told to conduct
due diligence on the highest volume
material as a starting point for
compliance. For example, if cotton
makes up 60% of your shipment, you
would prioritize tracing this supply
chain. But if materials that make up a
small percentage of your shipment are
also at risk of detainment under the
UFLPA, does this advice still ring true?
I think the risk-based approach to UFLPA
due diligence is an appropriate response
by the industry. You have to start
somewhere, so starting with your high-risk
commodities makes sense. Cotton, over
the last three or four years, has been
prioritized for enforcement, but for the last
year, we’ve seen thousands of other
shipments being detained for purposes that
have nothing to do with cotton. You might
you have to figure out how to walk and then
run with all your other materials. 
It’s a mindset shift from an enforcement
perspective. There is no other law in the
U.S. that says you’re guilty as an importer
until you can prove your innocence. The
rebuttable presumption [a legal principle
that presumes guilt until innocence can be
proven] sends a clear signal to the industry
that proactive due diligence is now a legal
requirement. 
Forced labor legislation is emerging in
The Dutch Child Labour Due Diligence
Act, the UK’s Import of Products of
Forced Labour from Xinjiang
(Prohibition) Bill, and the European
Parliament’s
22
Proposal For a Ban on Goods Made
Using Forced Labour. How do they
compare to the UFLPA and does
compliance with one forced labor law
mean your business is compliant
globally?
those businesses? Would you
The rebuttable presumption is a very
unique part of the U.S. regulatory regime.
The reason it was added was because
many in Congress believed it was the only
way that industry would comply with the
law to the fullest extent. If you look at the
other laws that have passed or have been
proposed for forced labor bans, a
rebuttable presumption is not included. 
that approach were caught off guard and
From a regulatory and compliance
perspective, brands need to comply with
the UFLPA if they have U.S. business. But
the UFLPA is so strenuous that it will help
enable them to comply with European laws
and, if the UK strengthens its modern
slavery legislation, it would help with
compliance with that too. The same goes
for Canada, Mexico and other jurisdictions. 
can’t be achieved by flipping a switch.
However, it’s not the other way around. If
you’re a European or UK brand and you’re
concerned about the proposed EU bans,
complying with those doesn’t mean you’re
in compliance with the UFLPA.
The way the UFLPA works, if you collect
the data, do the mapping and implement
traceability, you’re going to have the
majority of the regulatory documents that
you need to comply with the proposed
forced labor bans around the world. 
Many fashion businesses have been
slow to react to and prepare for
legislation, despite often getting a few
years of advance notice. What impact
has the rollout of the UFLPA had on
recommend a different approach? 
When the UFLPA was signed into law in
December 2021, a lot of brands took a
wait-and-see approach to see what the
regulators would do. [In June 2022], the
regulators came out at 100 miles an hour
and started enforcement rapidly from day
one. As a result, the businesses that took
had their goods detained at the border.
They went through very long, expensive
applicability reviews to see if those goods
could be released. There was a huge
amount of risk that they would be caught
flat-footed once enforcement began. 
It boils down to how quickly companies
recognize and appreciate that traceability
Implementing traceability and supply chain
mapping takes time. It takes months to find
that information and get it from your
suppliers and their suppliers, all the way
down the chain.
So if you wait until the law is being
enforced, you’re already months behind.
You risk regulatory action and being called
out publicly by NGOs, political leaders, or
the media, which would pose a significant
reputational risk.
23
Interview: Anticipating and Preparing for
Incoming Laws
Baptiste
It’s complicated, yes. But it’s manageable.
Carriere-Pradal
You need to be able to understand the
Chair of Policy Hub and
co-founder of 2BPolicy
The fashion industry is facing a wave of
legislation. In the next five years, ambitious
lawmakers in the EU, U.S. and UK will
require fashion companies to track,
measure and report on a wide range of
social and environmental issues, from
forced labor to deforestation and beyond. 
Despite this, few businesses are ready to
take the necessary steps towards
compliance, says Baptiste Carriere-Pradal,
chair of Policy Hub, an organization that
represents the apparel and footwear
industry to propose policies around
sustainability and circularity.
collection depending on identified risks and
“Too many brands wait until the ink is dry
on regulations before they do anything, and
that’s where the problem lies,” he says.
“Very few brands want to anticipate
regulations, but we can already anticipate
the majority of the data points that they
need to capture.” 
emissions,” he says. “To have a fair
Some industries face one major challenge
— the aviation industry is primarily
concerned with decarbonization, for
example — but fashion faces a variety of
issues.
complexity of the issue at hand to be able
to implement a proper solution.
“
“While talking to major brands, many of
them are members of tens or hundreds of
initiatives focusing on forced labor, child
labor, living wages, health and safety,
carbon, water, ocean waste plastics, you
name it,” says Carriere-Pradal.
“This is an industry that has so many
challenges to tackle with so few means.
The reality is however that with the
available means and time, we won’t be
able to solve everything in the next 5 to 10
years. We need to prioritize, then brands
should have a phased approach to data
legislation.” 
So where should brands focus their
attention? Carriere-Pradal says there are
four requirements that brands should be
prioritizing. “The first element brands will
have to disclose is their scope 3
approximation of this, you need to know
your materials mix and the country of origin
of this raw material.” Next are requirements
for deforestation and forced labor.
24
“For both of these, the primary information
required is the exact origin of a good. In the
case of deforestation, you need to know
the origin of the hides you import. Then,
you need to be able to trace the origin of all
your risky raw materials given the forced
labor regulations.”  
“But they tend to be systematically
underfunded, under-resourced, and the
staff are stretched,” says Carriere-Pradal.
“When you have one person leading
‘decarbonization’ for a full company, with a
limited budget, what is exactly the expected

output?”

While some of these requirements won’t be
implemented for a few years, Carriere-
Pradal says that brands should start
collecting a wide range of information from
suppliers now to anticipate future
regulations. “It’s easier to gather a lot of
primary data and then you can improve
Carriere-Pradal’s final message for the
industry is a word of warning: “You are
likely to overspend millions on fast tracked
solutions if you don’t anticipate the impact
of the data that will go public on your
shareholders, customers, and
stakeholders.”

over time,” he says. “The issue here is that

if you’re too selective, you might have blind “Companies need to anticipate upcoming
spots.”

legislation, work with their peers, identify

adequate solution providers, and develop a
Undoubtedly, partnering with a traceability compliance road map to allow a smooth
solution provider is the only way to gather transition from a unregulated sustainability
and sort the scale of data needed to meet strategy to a fully regulated one.”

these requirements. “A brand wouldn’t have

the capacity to do this alone because it
requires a huge amount of effort. You need
to have a traceability solution to do this
work,” says Carriere-Pradal. “It’s
complicated, yes. But it’s manageable. You
need to be able to understand the
complexity of the issue at hand to be able
to implement a proper solution.”  

He believes that brands must invest heavily

in building robust sustainability teams
staffed with experts who have the budget
and support from key stakeholders to make
rapid progress. “In the past and still today,
sustainability teams are a ‘nice to have’ for
many brands.

25
THREE SECRETS TO SUCCESS
1.
Map out data requirements for these
laws, as well as the data you already
have available in high quality. This will
help you discover gaps you need to fill,
or existing data you need to improve.

2.
Analyze the regulatory
landscape with current and
incoming laws versus your risk
profile, to understand which laws
to prioritize first.

3.
Set up a roadmap with prioritized laws, when they come into
force and the data requirements connected to them for your
business, so you have a clear overview of the data you need
to collect by when to ensure compliance.

26
ENSURING YOUR
ORGANIZATION IS ALIGNED
AND READY

OUTCOME OF THIS CHAPTER

This chapter will help you to recognize

the role of internal and external
stakeholders in achieving your
traceability goals. You will hear from
Matthew Xu from ASICS and Sherry
Fazal from Tapestry, who share their
journey to organizational alignment.

27
ENSURING YOUR ORGANIZATION IS
ALIGNED AND READY

The success of your traceability initiative What is External Alignmenta

starts long before the right solution provider
has been chosen. After you have defined
your business and sustainability needs, the
next step is to ensure internal and external
alignment and readiness to take on a
traceability solution. 
 Ensuring suppliers understand why and
how a traceability solution is being
adopteo
 Ensuring suppliers understand the
incentives for compliance and risks or

penalties for non-compliancZ

Without buy-in, support and collaboration
from your key stakeholders within your
organization and your supply chain, it
would be impossible to create a cohesive
and unified strategy. We will elaborate on
the points below in the next chapter: How
to Make Your Implementation Successful. 
 Alignment with service providers —
their data needs to feed into your
traceability platform so it’s essential that
different systems are able to talk to one
anothem
 Leveraging your supplier relationships to
partner with them on this program

What is Internal Alignment?<

 Putting together your cross-functional
traceability team<
 Defining a clear responsibility
assignment matrix for internal teams
For example
 The IT team is responsible for data
integrations<
 The local buying office is
responsible for supplier alignment<
 Setting a budget<
 Creating a realistic timeline of priorities
and milestoneG
 Identifying and communicating with key
stakeholders from relevant teams,
including the C-suite

28
Assess Your Readiness Some of the tasks that the supplier
engagement team will have to perform
The traceability solution you choose will include:

depend on your organizational readiness `

and maturity. Do you have the in-house
personnel needed to work with a
traceability solution provider? Where is
your data held and how accessible is it? Do
you have contact with your suppliers?
Readiness can be defined in three
aspects: 
B Engaging your community of suppliers
and educating them on the importance
of their cooperatioK
B Outline the vision for sustainability
beyond compliance by setting out your
environmental values and goalT

B Training suppliers to upload information

to your chosen traceability platforV
Data Readiness
B Regular monitoring to ensure supplier
To work with any traceability solution, complianch
companies need a solid foundation of B Responding to issues and queries from
master data — information on products, suppliers to ensure a smooth uptake

suppliers and purchase orders — to ensure

these entities are referred to in a consistent Across the world, garment suppliers
way across systems. The quality, operate at the control of brands and are
granularity and location of your data all often treated as disposable. But brands
matter here. 

beware: a traceability program won’t

succeed without the collaboration and
To assess your data readiness, identify the cooperation of your suppliers. Developing
systems currently holding your brand’s data strong relationships built on mutual respect
and the availability of that data, as this will is crucial. 

have to align with the traceability solution’s

data structure. This task will require a
dedicated effort by your IT team to
understand data mapping and establish
integrations that can push your master data
into the traceability system. 
Suppliers should be supported and
motivated to share their data and help you
achieve your traceability goals. Companies
can encourage supplier engagement by

offering incentives such as guaranteeing

them more business, paying a premium for
Supplier Engagement
orders, connecting them to sustainable
At the core of any traceability program is supply chain financing and reducing
the relationships you have with your payment terms. 

suppliers. To manage the constant

communication and collaboration with
suppliers, brands must factor in sufficient
bandwidth, personnel and organizational
structure.

29
 This will be driven by two critical factors:
Sourcing Models

your sourcing model and the quality and

maturity of your master data. 

How and where you start your traceability

journey will determine the success of your
These tables sets out three of the most
implementation. Working with your
common sourcing models, the
traceability solution provider, analyze the
requirements for internal readiness and
overall objectives to create a plan for your
realistic goals for the short-term:
program launch.

Sourcing Model Cut Make Trim

Typical Features Brand owns the design & sourcing and controls production

Definite visibility up to T2 suppliers, with the exception of small

components like threads 

Nearly full knowledge (90%+) of the bill of materials used in the

finished product.

More commonly used by high-end and luxury brands

Internal Ensure sourcing partners have needed bandwidth to interact

Readiness with CMT and T2 suppliers

Needed
Ensure IT team bandwidth for enabling integrations (data in &
data out)

Ensure business team bandwidth to define requirements from

various stakeholders

Short-Term Identify T3 & T4 suppliers

Goals
Establish COC from yarn (or T3 stage) to finished goods

30
Sourcing Model Full Package Program with Garment Supplier

Brands own the design and work with T1 suppliers

Typical Features

Brand purchases at fixed cost from the garment manufacturer, but may also

nominate suppliers

Brand has less responsibility & risk, but also less control and data

Cost per garment higher than CMT

Ensuring sourcing partners have bandwidth to interact with T1 & T2 suppliers

Internal

Readiness Establish change management team to work through different phases of

Needed program

Team to engage with T1 as workload will be higher for T1 in coordinating all/

most of the data

Ensuring IT teams bandwidth for ensuring integrations (data in & data out)

Map lower tier suppliers beyond T1

Short-Term

Goals Establish the BOM for all products

Establish COC from fabric stage to finished goods

Sourcing Model Full Package Program with Agents

Brand outsources the design, sourcing and production to external agents

Typical Features

Brand may use this as their core business model or for specific product

categories

More commonly used by fast and ultra-fast fashion brands

Brand has less responsibility and risk regarding delivery and quality, but also

less control and data

Internal Ensuring sourcing partners have needed bandwidth to interact with agents  

Readiness Change management team to work through different phases of program . This

Needed fundamentally changes the current business model, as in current setup

agents take all the risk and workload .We expect this to change with

increased transparency in the supply chai n

Ensuring IT teams bandwidth for ensuring integrations (data in & data out)

Map the supply chains through agents

Short-Term

Goals Establish the BOM for all products

3 1
Key Considerations

Implementing a traceability strategy without

the support and alignment of all your key
stakeholders is like building a house
without a blueprint — the result is unlikely
to resemble your vision or fit your needs.

The right solution for your business will

emerge from discussions with internal and
external stakeholders, taking into
consideration the wider business goals, as
well as your company’s sourcing model
and data maturity. Keep in mind: this
process could take months, but significant
investment decisions shouldn’t be rushed.

After the case studies in the next chapter,

you’ll discover the full spectrum of
sustainability solutions on the market to
help turn this plan into action.

32
THREE SECRETS TO SUCCESS
1.
Involve and align everyone across functions, from IT and
sourcing to sustainability, legal and marketing. Ensure all
stakeholders are on board and understand their role in this
transformation.

2.
Collaborate with suppliers. Bring them along for the journey
and consider them equal partners in this transformation. Build
strong relationships built on mutual respect to ensure a
successful program rollout.

3.
Prioritize based on risks and urgent
needs. You can’t solve every problem
at once, so create a realistic timeline to
achieve tangible goals.

33
Case Study: Launching the ASICS

Traceability Transformation

The ASICS traceability initiative is a

Matthew Xu
corporate transformation from a linear to a
CSR and Sustainability
circular business model. I believe it is
Lead at ASICS
crucial to approach this like any other

transformation project.

“
When people think about traceability, many When we made the decision to collaborate

brands are still struggling to establish a with TrusTrace, we conducted brand

comprehensive process to address it. In my meetings to introduce their platform to the

view, this represents a transformative ASICS team. We emphasized the unique

endeavour. Drawing on my years of value TrusTrace offered compared to other

experience in corporate transformations, I solution providers we had considered.

believe it is crucial to approach this like any TrusTrace made it easy for me by demo-

other transformation project.

ing the platform and assisting in articulating

our plan.

The ASICS traceability initiative is a

corporate transformation from a linear to a The project charter encompasses

circular business model. Traceability plays opportunities, goals and objectives related

a vital role in achieving transparency — not to responsible sourcing and product

only to share our story but also to integrity. It also outlines specific

exchange best practices and foster deliverables. In the short term, these

collaboration in addressing challenges. 

deliverables will help us address immediate

concerns and risks while achieving

To effectively lead such a transformation, operational excellence and efficiency.

discipline is paramount. With the Whenever the project swings off track, the

assistance of TrusTrace, we developed a charter serves as a compass to realign

robust project charter — a guiding everyone.

document that ensures our team

understands the project’s essential We had three main deliverables:

aspects, success indicators, and developing and implementing the

expectations, thus keeping everyone traceability system, ensuring its adoption

focused. Putting everything in black and by our employees and suppliers, and

white on paper facilitates understanding integrating it with our existing supply chain

throughout the organization. management systems.

34
This integration aims to not only drive
efficiency but to enhance business
resilience. 

From a strategic standpoint, we closely

monitored upcoming laws that would affect
us. For instance, the UFLPA highlighted
cotton as the primary material subject to
mandatory traceability. Accordingly, we
determined the highest-volume products
and identified the appropriate traceability
tiers.  

By creating a project charter, you can help

your colleagues comprehend the various
project phases and plans to pave the path
for implementation. Articulating this to the
management team instills confidence.

The initial step involves running diagnostics

to understand the current challenges and
the urgency for change. Then, we must
guide people in envisioning the future —
how the transformation will benefit the
company — not just in terms of traceability
and sustainability but also for the business
itself to drive resilience.

It’s important to connect the project vision

to the broader company’s mission, as it
resonates with those focused on business
objectives.

For ASICS, our commitment to a better

world revolves around enabling everyone
to live healthy lives through mental and
physical activity. This mission is the driving
force behind our Mission 2030 initiative,
which seeks to establish a holistic
framework of responsible sourcing and
product integrity.
35
Case Study: How Tapestry Ensured
Organizational Readiness
Sherry Fazal
We believe that being partners, rather than
Sr Manager,

Global ESG & dictating our demands, is key to how we

Sustainability Solutions are seen by the suppliers in our value chain
at Tapestry

The commitment to this journey was driven

from the top down; our leadership was
behind us from day one. A full ESG/
Traceability team was not in place at that
point, but the dedication and drive to move
“
We believe that being partners, rather than
dictating our demands, is key to how we
are seen by the suppliers in our value
chain. We believe this will drive their
willingness to participate.

the needle forward were strong. 

The launch of Coachtopia, our new sub-

We already had a master data hub for
Product Lifecycle Management, Materials
Management and Enterprise Resource
Planning data in a centralized repository.
The next step was understanding how to
slice and dice the different pieces of data to
get accurate ESG/Traceability reporting.
brand focused on circularity, was a great
opportunity to get our new vendors on
board from day one with the ground rules
for how we wanted to map Coachtopia’s
traceability journey.

Our supply chain analytics team had

already been working on end-to-end
visibility of our supply chain, using
dashboards and exception reporting, which
helped enable us to make better decisions.

It was our chief supply chain officer’s job to

communicate our journey, including what
we wanted to accomplish, explain what we
need from our suppliers, and find out what
they need from us.

36
Find the Right Solution

for Your Needs

OUTCOME OF THIS CHAPTER

There is no shortage of technology

solutions on the market today. In this
chapter, Fashion For Good Innovation
Analyst James Crowley breaks down the
types of technology solutions on the market
and shares key innovators in each category
to shine a light on the companies driving the
industry forward.
37
Find the Right Solution for Your Needs

by Fashion For Good

Fashion companies should consider these
James Crowley

Innovation Analyst at
innovations as part of a portfolio of partners
Fashion for Good that work together, sharing information to
achieve their goals.

At Fashion For Good (FFG), we have seen

a rapid rise in innovation catering to the
growing demand for traceability and
sustainability solutions in recent years.
Traceability innovation can enable
improved inventory management, impact
calculation and scope 3 data integrity. It
“
All supply chain stakeholders involved in
reducing the negative impacts of sourcing
decisions and improving the integrity and
credibility of supply chain data need to
understand that traceability involves a
constant pulse of oversight and
governance.

can also assist brands and retailers to meet

the disclosure requirements of incoming In a sense, the term ‘traceability
supply chain due diligence policy.
implementation’ should be swapped for
This innovation consists mostly of Software ‘traceability maintenance’ once digital or
as a Service (SaaS) digital platforms that physical traceability service providers have
can map, track, and help verify information been chosen to meet sustainability
on suppliers, materials, impact, and ESG objectives. 

credentials associated with the life-cycle of

products sourced.

Read on for a deep dive into transparency

and traceability innovation in the textile and
There is no singular traceability solution footwear industry.

that meets all of a user's business and

ESG needs. Fashion companies should
consider the below innovations as part of a
portfolio of partners that work together,
sharing information to achieve their goals.

Different innovations target different ESG

and business use cases.

38
The Traceability
Innovation
Landscape
Sourcemap
Supply Chain Traceability
Platforms
social data points needed for credible
Supply chain traceability platforms are
blockchain or cloud-based solutions that
provide supply chain mapping &
visualization tools and perform material &
product traceability.
They are used to consolidate and verify the
chain of custody documentation
(transactional certificates, scope
certificates and associated sustainability
standards), perform supply chain mapping,
facility profiling, batch and product
traceability, and allow API integration with
brands/suppliers' internal systems.
visibility and oversight over their impact
These solutions have a wide scope of the
supply chain and have the capacity to
cover scope 3 (or Tier 1 to 4).
For supply chain traceability platforms, a
key distinction is between fiber forward and
garment backward approaches.
environmental impact from suppliers,
Service providers with fiber forward
capabilities allow for real-time and secure
digital identities to be created in parallel to
the commodity flow. Garment backward
approaches follow a more traditional
approach, mapping the supply chain from
the finished garment backwards.
Key innovators:
TrusTrace
Textile Genesis
Retraced
Altana
Key Use Cases-
3 Enabling the visibility and digitization of
product, supplier, environmental, and
policy disclosure.
3 Providing data integrity and system
validation for material and product
certification (such as Textile Exchange's
standards).
Impact Trackers
Impact trackers are digital solutions that
take primary data from suppliers to
measure several indicators, including
carbon emissions, water and energy
consumption, land use and biodiversity
impact. This allows companies to have
hotspots. From here, they can identify
areas to reduce emissions and prioritize
actions that will reduce their overall carbon
footprint. 
Impact trackers serve as calculating tools
to measure a company's indirect
customers, and transportation. These
emissions are typically more difficult to
measure and manage than a company's
direct emissions (Scope 1 and Scope 2),
but they can represent a significant portion
of a company's overall carbon footprint.
39
Key innovators:
waste recycling, helping to guide the
Made2Flow
transition of waste to resources in the
Vaayu
fashion industry.

Glimpact

PEFtrust

Key Use Cases"

Consumer Engagement

7 Meeting the requirements of the

Mobile applications that perform
Product Environmental Footprint (PEF),
sustainability ratings on fashion brands for
part of the Single Market for Green
consumer visibility. They use rating
Products Initiative launched by the E&
systems that aggregate standards,
7 Measuring and reporting on internal
certifications and publicly available data
sourcing decisions and sustainability
into accessible scores. This promotes
commitments that have been
transparency across the fashion industry.
established within the company

Customers can use these applications to

stay informed on the ethical and
Circularity Platforms sustainable credentials of brands in order
to make conscious purchasing decisions. 

(Waste Mapping)

Key innovators:

Circularity platforms for waste mapping are

Good On You

blockchain and/or cloud-based digital

solutions. They focus on mapping textile
Key Use Cases"
waste supply for collection, segregation,
7 Consumer engagement with institutional
and recycling purposes. These digital
sustainability rating–
solutions provide data analytics into
7 Can potentially integrate with Digital
volumes, composition, and geo-locations of
Product Passports in the future, linking
waste flows. They enable clarity on waste
brand ratings to product impact analysis

availability and key institutional contacts

required to connect the supply to the
demand of textile waste.

Physical Tracer
Key innovators:

Reverse Resources

Technologies

Satma

Both additive and forensic tracer sub-

Recycle Re_fashion

categories are used to trace and

authenticate fibers and materials, as well
Key Use Cases:

as prove supply chain and geographic

Essential service providers to facilitate the
origins. Additive Tracers are physical
scale of both pre- and post-consumer
additives which are applied to the fibers
textile
and materials on the supply chain floor and
40
detected later to prove their origin. Forensic Social Innovation:

Tracers are technologies that analyze the

micro-particle and biochemical composition Reporting tools enable businesses to listen

of fibers and materials in order to prove and respond to workers and make

their origin. 

improvements in their working conditions

across their business and supply chain.

Key innovators:
This is usually done via a mobile phone

Oritain (Forensic Tracer)

app/call which allows for direct feedback

Haelixa (Additive Tracer)

from workers throughout the supply chain,

using surveys and mobile voice technology.

Key Use Cases:

Catalyzed by incoming corporate due Key innovators:

diligence legislation like the UFLPA, the &Wider

demand to integrate tracer technologies Ulula

into global fashion supply chains has risen. Labor Solutions (WOVO)

This allows companies to prove the

geographic and supply chain origin of Key Use CasesI

sourced fibers in line with the pressing F Compliance with the EU Human Rights

demand for physical verification alongside Due Diligence laws.i

the site and transactional verification. F Achieving internal sustainability and

social impact commitments

41
Fashion for Good’s

THREE SECRETS TO SUCCESS

1.
Create internal team positions focused on1
5 Policy advisory for supply chain legislation evolvement"
5 Traceability integrity for product certification, circularity, and policy data
disclosures (focus: environmental sustainability.
5 Transparency integrity for supplier mapping, working conditions, and HRDD
policy data disclosures (focus: social sustainability)

2.
Categorize your supply chain data into “obligatory data
need” or “non-obligatory data need”, based on business
priorities (e.g. meeting policy disclosure, verifying material
certification, impact tracking for climate disclosures)

3.
Choose traceability service
providers that align with your short-
term needs, as well as your long-term
goals. Look at this as a long-term
investment, and partnership.

42
Case Study: How Tapestry Found the
Right Solution for Its Needs
We knew that there wouldn’t be a single
Sherry Fazal

Sr Manager,
solution that met all our needs, but one that
Global ESG & would fulfill 80-90% of our ESG/Traceability
Sustainability Solutions needs would be a great place to start and
at Tapestry give us the answers we needed.

We knew we needed to find a solution that

“
Basically, every partner that would use the
fulfilled the needs of four core functions: system for ESG, CSR, or Traceability
General/Administrative/Reporting, Supplier reporting.

Capabilities, Product/Materials Tracking,

and Traceability. We had an extensive We set up a scoring system for each
Request for Proposals (RFP) process that vendor and worked with our cross-
took nearly a year, during which we looked functional partners to select one solution. It
at several systems.

was a laborious project, no doubt, but as a

company, we felt that the TrusTrace
We clearly defined our ideal system’s must- solution offered so much more than a
haves, should-haves, and nice-to-haves. traceability system.

We needed an integrated solution not only

with pre-built APIs and established Since we’ve started using TrusTrace, the
connections with platforms like the Textile platform has become our ESG tracking
Exchange and Worldly [formerly the Higg system and is becoming a part of our DNA.

Index], but one that was able to grow and

flex with us. 

We knew that there wouldn’t be a single

solution that met all our needs, but one that
would fulfill 80 to 90% of our ESG/
traceability needs would be a great place to
start and give us the answers we needed.

We identified who our key internal

stakeholders were, including the Vendor
Onboarding and Compliance team, the
Traceability team, and the Materials
Management team. 43
HOW TO MAKE YOUR
IMPLEMENTATION
SUCCESSFUL

OUTCOME OF THIS CHAPTER

This chapter will give you a solid

understanding of the tools needed for a
successful traceability solution rollout
and the key considerations for
reviewing, analyzing, and expanding
your initiative.
44
HOW TO MAKE YOUR IMPLEMENTATION
SUCCESSFUL
We have established that the successful
implementation of any traceability program
starts with careful planning and a
structured approach to ensure the highest
chances of success. Now, you’re preparing
to launch. But where to start?
is unique, having a workshop with all
Timeline and Planning
requirements and finalize the business
Once you’ve picked a solution provider,
partner with them to establish a plan for
achieving your goals within a specific
timeframe. A solution provider with a strong
understanding of the complexities of a
program rollout will be crucial. In addition to
the platform capabilities, strong program
management support from the solution
provider has proved to be a key ingredient
for successful rollouts. 
^ Take a phased approach. Having a
Your solution provider should have a strong
program governance structure, mature
tools for program tracking, a well
established communication matrix, and a
proven support process. This establishes
transparency of task ownership, risks, and
project status, helping you to prioritize
actions and make progress.
Some key aspects of developing a
implementation plan:f
^ Kick off the project with a proper
discovery phase. Since every program
stakeholders to align on the
priorities is critical.f
^ IT integrations often end up as bottle-
necks that delay implementation, due to
late involvement and limited bandwidth
of IT teams. Involving IT teams early,
and creating a clear systems integration
plan, is critical to keep the project on
track.f
multi-phase project plan with different
goals has usually proven to be
successful. In the initial phases, to get
some immediate success and
momentum behind the program, you
might choose to get started without
proper IT integrations and focus on
easy wins. Gradually, you can increase
the levels of integration needed and
outcomes expected.
45
Prepare for Program
Rollout
responsible for launching and managing
Supplier Communication
Accessible and detailed communication
with all your direct suppliers about the
importance and value of their role in your
traceability program is critical for success.
 Perform all required activities on the
At a minimum, brands should articulate
 Why are you launching this initiative
 How critical this initiative for your
busines
 How can it impact your business with
the supplier
 How and why your suppliers play an
integral role in its succes
 What the traceability system is being
used for and the details of its rollou
 Plans and timelines for training and
suppor
 Information about the point of contact in
your brand for supplier queries
facilitate data movement into the
Establishing a Team
Your business will need a core team
the traceability solution. This team will:
Tu Be the super users of the solution:
 Learn how to use the traceability
solution
platform
 Work with the solution provider to
configure, test and fine-tune the
system before rolling it out to
suppliers
>u Actively manage the program
rollout:
 Discuss and align with solution
provider on program rollout
 Attend regular program review
meetings
 Suggest improvements to the
platform or rollout approach
 Work closely with your IT team to
traceability systeZ
hu Coordinate with various teams toj
 Train suppliers on how to use and
make the most of the traceability
solution
 Interface with business teams to
ensure data from the traceability
systems is consumed in the most
effective manner 
46
Platform Rollout

This should be a time-bound activity so that

any improvements can be made to your

Launching a traceability program requires program before it is implemented at scale.

participation from your wider supplier Below, you see an example of a program

community, so effective change roadmap.

management is essential. First, prioritize

your objectives within a timeline, so that

you can track your progress throughout the Delegating Responsibilities 

program execution.

There are certain tasks that will be

managed by your solution provider, by your

At TrusTrace, we recommend working with suppliers, and by your company.

a small subset of your supplier base that Understanding the scope of your

can act as a case study to understand responsibilities helps keep each

various aspects of the program rollout, stakeholder accountable for their actions.

before the large-scale program.

On the next page is an example of how a

Starting small enables you to engage project team can be set up to ensure

closely with your suppliers, monitor their clear roles and responsibilities for

compliance, uncover challenges, receive implementing traceability.

feedback, and correct course accordingly.

47
Project Team, Roles and Responsibilities

Project Owne/
5 Align on vision and objective$
5 Buy in with managemen
5 Align on resource availabilit'
5 Budget approval


Potential People: Head of Compliance/Head of

Business/Head of Sustainability

Project Management Officv Steering Committev

5 Manage program plan and ensure program is on-track^ 5 Program Governance^
5 Ensure cooperation from teams and vendor$ 5 Review progres$
5 Set goals and timeline$ 5 Make intervention$
5 Reporting and tracking

5 Decide on prioritie$
5 Sign off on acceptanc
Potential People: Sr. Leaders from different divisions.
 5 PNL ownership

Direct reporting to Project Owner/Steering Committee

Potential People: Head of Business Units, Head of Sourcing,

Head of IT, Legal/Compliance Teams

Project Manager•
5 Day to day program managemen
5 Track actions, items, deliverables and manage risk$
5 Communicate progress with key stakeholder$
5 Handle requirements and prioritizations from various stakeholders

Potential People: Sr. Program Manager who can handle change management
aspects

Project Lead 1
Project Lead 2
Project Lead 3
Project Lead 4
IT Team Lea
(Supplier Relationship 
 (External Comms (Legal and Complianceà (Key Account
Managementà Marketingà Managersà áÞ Integration$
áÞ U.S. Legal Team$ ½Þ Security
áÞ Representatives from áÞ End consumer comm$ ½Þ EU Legal Teams

áÞ KAM Customer Ê assessmen

local sourcing office$ ½Þ Corporate ½Þ KAM Customer 2

Þ User provisionin
½Þ Procurement team communications Þ Change
management

Coordinate with suppliers
on
áÞ Introducing the
traceability program –
importance and how
you plan to rollou
½Þ Coordinate supplier
trainin
Þ Ensure supplier
complianc
Þ Decide the initial list of
supplier$
Þ Share supplier
feedback to solution
provider for
improvements
Work with key business
customers and align on
data needs
áÞ Manage integrations
with existing IT
system$
½Þ Handle user
provisioning, security
assessments,
architecture review$
Þ Manage change
management requests
and implementations
áÞ Align on consumer áÞ Lead on the data
communication plan: needed for regulation
what data, frequency compliance^
of updates, view for ½Þ Prioritize relevant
end user$ regulation complianc
½Þ Align on Supplier Þ Finalize data sharing
disclosure plan: what format with regulators
tier of suppliers, what
datO
Þ Align on reporting
requirements and
data needs

48
Supplier Training

Effective participation from all

Together with the solution provider, your
traceability team will need to plan and set
up training sessions for suppliers. While the
solution provider can handle questions
directly related to their platform, you should
facilitate these sessions, given your direct
relationship with suppliers. In these
sessions, you can answer questions and
communicate the objectives of the
Establish regular catch-ups for
program. To run effective training sessions,
you should consider the following
Group your suppliers to be trained
based on geography or value process
so that the information covered and
questions answered during these
sessions can be relevant to their role in
the supply chain. usage.
suppliers. Tracking their participation in
training sessions is critical for them to
continue doing business with youV
Create custom documentation that
provides precise instructions for your
suppliers to follow. These can also be
referred back to at a later dateV
suppliers to share their challenges and
solutions with each other, facilitating
information sharing across your supply
chaie
Training in local language has proven
to be a crucial factor in addressing
some of the key challenges of platform

Share information about the

traceability solution provider ahead of Support Readiness

the training session so that suppliers

can come prepared. Internal teams and suppliers can’t be
expected to adopt a new traceability
Trainings after upgrades and new solution without support. Before you
releases. With the growing launch, understand the systems that your
requirements around traceability, the traceability solution partner has in place to
solution provider is expected to update help the users of their platform. The
the system for additional capabilities support system should typically have:
orto decrease the workload. Ensuring
the users are trained on what is new Easy to understand user manuals
and what is updated is critical. Support videos
Real-time chat support to address
Make your training interactive by unanswered questions
engaging suppliers with Q&As and Webinars around new updates or
quizzes. This will encourage discussion upgrades to ensure users don’t have to
and foster a deeper understanding of rely on support systems 

the platform.

49
A key factor for a low rate of adoption is
that users do not know who to ask for help
or they do not receive prompt support,
leading to delays. To ensure users can
access help when they need it, companies
should test the support functions and
clearly communicate the process of
requesting help to users. 

A typical service-level agreement with

suppliers should include a reasonable
response time and resolution time. Typical
response times should be in minutes to
ensure the users aren’t waiting for long
times and resolution times can be agreed
upon based on the priority of the issue
raised.

Key Considerations

In summary, there are five key aspects of

successfully implementing a traceability
solution that companies should take away
from this chapter. These include

To establish clearly what you want to

achieve and define the timeline for
achieving your goal

To involve all the necessary internal and
external stakeholders and establish the
responsibilities of each team

To foster continuous communication
and collaboration with supplier

To monitor the information collected to
see progress towards your goal

To fine-tune processes based on
learnings and feedback from your
suppliers

50
THREE SECRETS TO SUCCESS
1.
Support and incentivize your suppliers to participate in your traceability
program rollout. Work with your solution provider to ensure that effective
communication and support systems are in place.

2.
Analyze and action the data collected through your
solution to achieve ESG, traceability and compliance
goals. A traceability program will fail to create meaningful
change without tangible goals and data-backed decision
making.

3.
Learning from, evolving and
investing more in your
sustainability transformation as
time goes on. Look at your program
rollout as the first phase of a bigger
initiative that will develop over the
coming years.

51
Case Study: How Tapestry Launched a
Successful Pilot Program
Sherry Fazal
The long-term vision is to have traceability
Sr Manager,
and transparency throughout the entire life
Global ESG & cycle of a product. How we get there won’t
Sustainability Solutions be linear — that’s the important part. We
at Tapestry
learn, we tweak, we pivot.

A core program team is key for any

implementation. Ours was a lean team of
five: one person from IT, one person from
materials, one person from traceability, one
person from vendor onboarding, and one
person from our social audit and
compliance team.
“
Training is a key part and we learned
quickly that context is key. We don’t give
our suppliers the standard training guide.
Instead, we take all the information that we
believe is important and narrow it down to a
very precise session that has business

context in it. We lean into the narrative of

our story to encourage suppliers to use this
Those folks were at the head of the system.

program and their directives came from our

senior vice president of ESG. Their end-to- The long-term vision is to have traceability
end visibility was how we kept momentum and transparency throughout the entire life
and alignment throughout the project.

cycle of a product. How we get there won’t

be linear — that’s the important part. We
Luck was also part of our success: our tier learn, we tweak, we pivot.

one and two suppliers were already using a

few Tapestry systems, such as our Product
Lifecycle Management and Enterprise
Resource Planning in our COC pilot, so
getting them to use the new system wasn’t
difficult.
Our work in ESG is not an add-on or
something that we ‘should’ have — it’s a
key part of our business that is making us
more resilient and forward-looking. ESG is

part of our DNA as a company.

We built out storyboards to share our vision

of where we’re going and where we need
their help. We designed road maps that
clearly documented and trained on what
will be changing in their current process.

52
WHAT HAPPENS NEXT

OUTCOME OF THIS CHAPTER

In the coming chapter, discover what

it takes to create a better future for
fashion: standards, collective action,
and real-time data. Looking to other
industries for guidance, experts
share their insight and vision to
inspire and drive action in the
fashion industry. Discover what it
takes to create change from those
who have helped to successfully
transform their industries for the
better.

53
WHAT HAPPENS NEXT
Short-term action must be paired with long-
term vision for the fashion industry to take
meaningful, unified strides in the right
direction.
In the coming chapter, thought-leaders in
their respective industries explain what it
takes to create a better future for fashion:
standards, collective action, and real-time
data sharing.
collaboration is essential if we're serious
Standards body GS1 demonstrates the
value and power of a standardized
language for traceability.
rights abuses. 
We also take a look at the shipping
industry, which has proven that when
individual companies come together and
work to collectively solve a problem,
significant change can occur.
That means ensuring everyone has
access, whether they’re a small civil society
TrusTrace co-founder and CTO Madhava
Venkatesh also shares his vision for the
future of fashion where traceability is
inherently built into the industry.
First, a word from Natalie Grillon of Open
Supply Hub on the value of collaboration.
Natalie Grillon
Executive Director of
Open Supply Hub
Stakeholders across supply chains are
almost unanimous in the belief that
about tackling the intractable challenges
society currently faces — issues like
deforestation, climate change and human
At Open Supply Hub, we believe that
equitable access to high quality, open data
about global supply chains is the essential
building block to enable systems change.
organization operating on the ground in
affected regions, or a major international
corporation. 
We know from our experience working in
this way that, when everyone is able to
work freely with supply chain data,
opportunities rapidly open up to shift
industries onto a more sustainable path.
“
54
Interview: Standardizing Traceability
Industry-Wide
Karolin Catela
Product Specialist at
Standards Body,
make smart decisions. You can have far
GS1 Sweden
At TrusTrace, we have seen an uptick in
traceability initiatives launched by fashion
businesses, which is undoubtedly a step in
the right direction.
you use standards to connect and align
We believe, however, that establishing an
industry standard for traceability is the best
way to see meaningful results. Not only do
standards increase the speed of
transformation, but case studies across
other industries indicate risk reduction and
cost-savings for companies that embrace
standards.
creates a solid foundation that every
“In the textile industry, companies all have
their own way of identifying things,” says
Karolin Catela, Product Specialist at GS1
Sweden. “They’re exchanging similar
information, but they all do it in their own
way between the four walls of their
company.”
certain information with each other,” says
When information needs to be exchanged
between different systems, it’s often done
through PDFs, emails and Excel files,
where human error tends to impact results.
If you use standards to connect and align
data in a specific way, it’s much easier to
more control over how you use your data.
“
“If you type one or two digits wrong, you
could be dealing with another product or
batch number altogether,” says Catela. “If
data in a specific way, it’s much easier to
make smart decisions. You can have far
more control over how you use your data.”
GS1 knows a thing or two about setting
standards. In 1973, GS1 introduced the
barcode, which revolutionized the way that
the world shopped. Establishing standards
company within an industry can build upon.
Currently, individual companies are working
in silos and failing to collaborate, share or
learn from other players around them.
“There is always competition between
companies, so they don’t want to share
Catela. “That’s why GS1 is a neutral
partner. We have rules, we don’t discuss
prices or competitive information, but we
gather companies around a table to
discuss how to collaborate and move
forward together.” 
55
Regulation will be a driving force for the
standardization of fashion. “The Digital
Product Passport will force brands to
conform to a common way of exchanging
information,” says Catela. “Brands will need
to have 2D bar code or RFID. Imagine if
every company had a different way of
doing this — it will be very ineffective.”

Once the industry can align on common

goals, it will start achieving tangible results
sooner. “If companies are going to reach
their goals, they have to step up,” says
Catela. “Everyone is thinking about
circularity and sustainability, but there is
power in gathering all companies in a
sector. It’s a lot of work, but if they have a
common goal, things will move much
quicker.”

56
Interview: Taking Cues from the Maritime
Anti-Corruption Network
Cecilia
Müller Torbrand
I think we are a bit tired of taking part in
Chief Executive Officer
at The Maritime
impact.
Anti-Corruption Network
If fashion needs a blueprint for the power of
collective action on a global scale, it should
look no further than to the Maritime Anti-
Corruption Network (MACN), which was
established by a small group of shipping
companies in 2011.
or whatever you want to achieve, then it
Since then, it has evolved to close to 200
companies around the world, all working
together to eliminate maritime corruption. It
does so by developing and sharing best
practices, working with governments, civil
society and NGOs to find the root cause of
corruption, and gathering, analyzing and
responding to primary data across the
value chain. It provides an ideal case study
for fashion, which, despite a number of
industry initiatives, has struggled to create
any tangible reduction across its biggest
impact categories.
oriented,” she says. “You have to make
So how has MACN improved issues faced
by the shipping industry? “By focusing on
actions and impact,” says Cecilia Müller
Torbrand, chief executive of MACN. “I think
we are all looking for that, regardless of
what area of sustainability you work in.
What is the impact of these initiatives on
various initiatives and not seeing the
“
the ground? How do you measure that?”
Müller Torbrand says that the storytelling
element is a crucial driver of action.
“Unless you hear stories of how your work
impacts individuals, local markets, villages,
becomes toothless. I think we are a bit tired
of taking part in various initiatives and not
seeing the impact.”
When it comes to building out industry
initiatives that have the power to shift the
needle, Müller Torbrand emphasizes the
importance of giving a seat at the table to
all stakeholders, from multinational
companies to local SMEs. “When you have
the value chain of customers and suppliers
sitting around the same table, you don’t
point fingers, you become very solution-
sure that everyone sits on the same terms.
A big company should be able to sit next to
the person who makes their products in
order to have a constructive dialogue.”
So who should foot the bill for these
initiatives? It’s a question that the fashion
industry has grappled with for years.
57
MACN’s founding vision ensures the
equality of all members, so its funding
structure reflects this. “Everyone who
comes into an initiative like MACN has an
equal voice,” she explains. “For example,
just because you are a large company,
doesn’t mean you have more rights to set
all the rules. However, it is important that
everyone make a contribution to the
initiative.”
chain, so it’s essential to prioritize urgent
Compliance with anti-corruption regulations
was a contributing factor in MACN’s
founding mission, but the fear of heavy
fines or prosecution was not enough to
encourage participation alone, says Müller
Torbrand. The main driver was the fact that
despite launching different programs to
tackle anti-corruption over the years, little
had improved for ship captains in their work
environment. “If your program has been
running for 10 years and you’re still facing
the same challenges, it might be time to
take another course,” she says. “That is
why sector-driven and industry-specific
initiatives are really important. They
immediately create common ground for
addressing risks and finding solutions
because everyone is working on the same
page.” 
“Don’t look for perfection. It’s important to
Gathering data through surveys, incident
reporting, operational improvements and
interviews is how MACN measures its
global impact, ensuring that the
perspectives of those who are most
affected by their work are heard. “You have
to survey the right people who know about
the risk so you get the right responses,”
says Müller Torbrand.
“If you get 20 responses and they’re from
people who actually work in the
environment you are trying to change, you
know if you’re on the right track.” 
Creating a positive impact doesn’t happen
overnight. Müller Torbrand says some of
MACN’s initiatives have taken almost a
decade to see results in the larger trade
issues first and build on positive impact to
grow the initiatives further.
Trying to tackle too many or too different
issues at once may mean that initiatives fail
to make a dent and lose the engagement of
their members or stakeholders. “Especially
in challenging markets where you have an
ocean of problems, you have to start with
one thing in one market, and then let that
create positive rings in the water,” she
says. 
The parallels between fashion and shipping
should give the apparel industry hope that
a unified transformation is achievable. Both
sectors are global, complex and face a
wide range of issues.
just get started and it’s better to start with
five companies than not starting at all,” she
says. “There was nothing unique about
what the shipping industry did with MACN.
It is something that can be replicated in any
topic and any industry.”  
58
Interview: Envisioning Fashion’s
Traceable Future
Madhava Venkatesh
become the norm. Nobody will worry about
Co-Founder and Chief
Technology Officer at
TrusTrace
Driving TrusTrace’s product and technology
vision, Madhava Venkatesh has his eyes
set firmly on the future of traceability in
supply chains. Backed by over 20 years of
experience in the technology space, his
vision is ambitious — targeting
inefficiencies and finding streamlined
solutions. 
throughout its entire lifecycle.
At the core of this vision is creating
industry-wide, standardized transparency
and data accessibility. “Today, information
exchange between brands and suppliers is
always on-demand — brands have to ask
their suppliers for something and the
supplier responds accordingly,” he says.
Connecting data to products would help
To collect data within this system, the
process is linear, manual and time-
consuming. “As a solution to this problem,
we should convert data sharing into an
individual transparency initiative for every
supplier in the network.”
imbalance, where conglomerates and big
Establishing network-wide transparency
requires the cooperation of all players in
the supply chain.
In the future, real-time data availability will
traceability, it shouldn’t exist anymore,
because it will be completely intertwined
into the business process.
“
If every supplier within the system collects
and attaches data — including social
practices, environmental practices,
materials movement, and other
sustainability information — to the product
and makes it available to all, then the
product and the data are interlinked
“If it gets to that stage where the
information is given voluntarily, it’s
standardized and can be handled by a
company like TrusTrace, then it becomes
very powerful,” says Madhava.
drive the circular economy, establish better
social and environmental practices, and
accurately measure the industry’s
footprint. 
Because of fashion’s built-in power
businesses hold the majority of power and
suppliers have very little, data is not shared
equally. “In fashion, a small brand doesn’t
have the power to convince suppliers,” he
says.
59
“We think that data exchange and access

shouldn’t be dependent on power

dynamics, because every brand and

manufacturer deserves to know their

product information.” 

Eliminating the friction of data exchange

and facilitating the ability to share

information is crucial to building this

transparent network of compliant and

connected players. This would shift the

industry from on-demand to real-time

information exchange. “In the future, real-

time data availability will become the

norm,” says Venkatesh. “Nobody will worry

about traceability, it shouldn’t exist

anymore, because it will be completely

intertwined into the business process.”  

In the last five years, education about

traceability technology has rapidly

increased, he says, but the industry needs

more participation and investment to fuel

growth and innovation.

“Technology is improving and as more

people use it, it will continue to improve.

We encourage everyone to be part of this

technology improvement,” says Madhava.

“As more people come in, more innovation

will happen, and it will only get better.” 

His final message for businesses still

hesitant to take the plunge on a traceability

solution: “You don’t have to start

everywhere. Start on the critical areas, and

the critical products, then go deeper. Don’t

be afraid to be ambitious. Without

traceability, there is no sustainability.”  

60
A CALL TO ACTION

61
A CALL TO ACTION
The fashion industry is under immense
pressure from legislators, consumers and
activists to tackle a wide range of urgent
issues. Until recently, there was little in the
way of guidance and support to help
fashion businesses navigate their
traceability journey. 
At TrusTrace, we recognize the knowledge
gap and have sought the expertize of
thought leaders from fashion and beyond to
fill it, starting with last year’s Traceability
Playbook. Our ambition with this Roadmap
has been to provide a step-by-step guide to
achieving your business-critical goals for
traceability, compliance and ESG.
The traceability landscape is constantly
evolving, and we can never claim to have
all the answers or the right solution for your
business.
needs to transform, paving the way for a
We hope that this step-by-step guide
supports you through each stage of your
business's traceability journey, from the
initial exploration to the rollout and
evolution. The templates and worksheets
embedded in this book will give you the
framework you need to get started.
Traceability Playbook, download your free
Below, you can find a helpful Glossary of
Traceability Terms and a Toolkit where all
supporting documents connected to each
chapter of the Roadmap have been
collated for easy access.
No matter how you go about it, we’re
confident of a few universal truths. We
know that capturing the right primary data
is important, but it’s vital that businesses
analyze, learn from, and make informed
decisions based on this data.
To make progress on your goals, a
thorough plan, timeline of priorities, and
buy-in from internal and external
stakeholders is also essential. We firmly
believe that collaborating with your
suppliers as respected equals is key to not
only a successful traceability initiative, but
a more equitable industry.  
While implementing traceability in fashion
is complicated, the work done by other
industries shows us that it’s not impossible.
Fashion businesses have all the tools they
more equitable, environmentally
responsible, and transparent industry. 
Want to learn more about how TrusTrace
can help your business to launch a
successful traceability program? Book a
demo here. To read TrusTrace’s first
copy here.
62
THE TRACEABILITY TOOLKIT

OUTCOME OF THIS CHAPTER

Apply the theory and insights you have

learned from the Traceability Roadmap
using the Traceability Toolkit. Use the
tried-and-tested templates and
worksheets to kickstart your
brainstorming, planning and
collaboration sessions with your
internal and external stakeholders.
63
Turning nsig ts nto I h I Action

Now that you have read the theory, it is time to turn insights into action. In the following
pages, you will find an example of ROI calculations, as well as practical templates to

support your traceability journey from the get-go. To make it easier to understand the

methodology and apply it, here is a sample brand that we have used as an e xample

throughout the toolkit.

Team Organization

Revenue
Products

USD $10 billion, with 60% from the Sells an assortment of products

US, 25% from the EU, 15% from including apparel, footwear and

Rest-of-World other items

Material exposure
f
Certi ied or Sustainable Materials

50% synthetic, 30% natural fibers, Currently 30% of the overall

20% animal fibers collection is made using sustainable

materials and the target is to

increase this to 90% of the overall

Distribution

collection by 2030
Sells through own webshop, e-

commerce platforms and multi-

brand retailers Sourcing strateg y

30% of products are sourced using

Sustainable Finance

FPP and 70% sourced through the

The company has also raised
CMT model with nominated fabrics
USD$500 Million in debt through

sustainability bonds where the h

Supply C ain

interest rates are tied to the Spread across the globe with a

following sustainability significant concentration in Asia

commitments:

Sustainability Commitments

1. Move 90% of production to certified supply chains by 2030

2. Get 20% more renewable power sources in the supply chain and decrease the

dependence on conventional power sources.

6 4
How to Calculate Return on Investment

Calculating the return on your traceability investment is an important way to prove the value

proposition to your company, driving buy-in from key business leaders. To define the ROI

for your traceability investment, you need to consider your key focus areas, and calculate

and evaluate your risk vs. investment needed.

Define Key Focus Areas:.

;A Compliance

2. Sustainable Finance

Based on the revenue share from various To support sustainable finance efforts, this

regions, key focus areas will be brand will have to track

The UFLPA, relevant for all products, The percentage of supply chains that

especially cotton, shipped from Asia to are sustainable and find alternate

the US. options for non-sustainable supplierk

AGEC, relevant for all products sold in Track the percentage of renewable

Franc1 power capacity across its supply chains

While the DPP and other EU due

diligence laws are also relevant, they For the project owner who is building out

are not yet in force and would therefore the proposal charter, it is imperative to

come as a lower priority, but included in measure the impact in monetary value.

the longer term scope.  

Considering that the brand has an active

strategy to increase certified and

sustainable materials, making the right

claims about its products is important to

Ensure the brand does not get called

out for greenwashing.

Support the demands from e-commerce

and multi-brand retailers on product

sustainability credentials

65
Calculate Risk

Here is how you could calculate the risks associated with the UFLPA, AGEC, and
sustainable financing.

1a. UFLPA

Assuming the brand has 3 shipments detained by the CBP under the UFLPA per year, the
cost to manually collect relevant documents and work with legal teams could be anywhere
between $60,000 andTasks
Scenarios $6.5 involved
million:

Breakdown of Total Cost 3

costs per shipments (USD)
shipment (USD)

Worst case Cost of data collection $10,000 + $6.5 Million

scenario + Legal fees + Cost of $100,000 +
holding the shipment $50,000 +

at port + Cost of $2 Million

shipment in case it = $2.16 million

can’t be allowed in the per shipment
US
Best Case Cost of data collection NIL + $20,000
$60K
scenario using a system + per shipment
Legal fees
Most likely
Cost of data collection $10,000 + $500K
scenario + Legal fees + Cost of $100,000 +
holding the shipment $50,000

at the port =$160,000 per

shipment
1b. C Assuming 20 of the overall
AGE % 2. Sustainable Finance. Assuming the
$2.5 billion in sales from the EU are sustainable bonds give an interest
attributed to France, the impact of not advantage of 200 basis points over the
having a solution can worst case mean $500 million loan, the interest differential
losing this revenue from the region, e ual
q could be $10 million if the business
to $500 million per year. While we do not doesn’t meet its sustainability goals.
yet know the penalties for non compliance,
-

a best case could be a fine on 2 3 of

- %

French turnover e uivalent to $10 15

q -

million.
66
Calculate Investment
Needed

For the sample brand, we assume that the

total cost of implementing a traceability
solution is around $1 million. This includes
the cost of the solution, cost of teams,
change management costs, and others.

Evaluate Risk vs.

Investment

Considering the key focus areas for this

brand, the monetary impact of failing to
comply with the relevant laws could be over
$30 million:B
$6.5 million for UFLP
$15 million for AGEC B
$10 million for sustainable loans

The total cost of implementing a traceability

solution at around $1 million for this size
brand, including the cost of the solution,
teams, change management and other
costs. With a risk of around $30 million,
mitigated with an investment of $1 million,
a traceability solution would provide an ROI
of 30 for these three focus areas alone. 

The same ROI calculations can be applied

to other business cases, such as due
diligence, supply chain risk analysis, and
implementing Digital Product Passports.

67
Define Your Vision, Goals and Milestones
for Traceability
Defining your needs is key to ensure you get the value you want to achieve out of your
program. It is also necessary to align stakeholders and resources. Below, read what this
could look like for the sample brand.

To complete the template, you can download the blank version here. While you are
focusing on year one, you may want to create rough milestones and objectives for year two
and three, pending on the priorities in your program roadmap.



68
Define Your Team and Establish Roles &
Responsibilities

Implementing traceability is a transformational program that requires a dedicated team with

clear mandate, governance and roles & responsibilities. Below, we have filled in a template
for setting up a project team and defining their roles and responsibilities. To make your own,
download the blank template here.

Project Owne]

c Align on vision and objectiveR

c Buy in with managemenN
c Align on resource availabilitU
c Budget approval


Potential People: Head of Compliance/Head of

Business/Head of Sustainability

Project Management Offic¤ Steering Committe¤

c Manage program plan and ensure program is on-trackŒ c Program GovernanceŒ
c Ensure cooperation from teams and vendorR c Review progresR
c Set goals and timelineR c Make interventionR
c Reporting and tracking

c Decide on prioritieR
c Sign off on acceptanc K
Potential People: Sr. Leaders from different divisions.
 c PNL ownership

Direct reporting to Project Owner/Steering Committee

Potential People: Head of Business Units, Head of Sourcing,

I
Head of T, Legal/Compliance Teams

Project ManagerÃ

c Day to day program managemenN

c Track actions, items, deliverables and manage riskR
c Communicate progress with key stakeholderR
c Handle requirements and prioritizations from various stakeholders

Potential People: Sr. Program Manager who can handle change management
aspects

Project ea L d 1
L d 2

Project ea L d
Project ea 3
Project ea 4
L d IT Team Lea0
(Suppl R l
ier e ation ship 
 (Externa lC
omm s (Lega anl omdC pliance (Key Acco nt u
Management  k
Mar eting  Manager s /, IntegrationR
/, U.S. Legal TeamR , Security
/, Representatives from /, End consumer commR , EU Legal Teams

/, KAM Customer  assessmenN

local sourcing officeR , Corporate , KAM Customer 2

7, User provisionin@
, Procurement team communications 6, Change
management

Coordinate with suppliers Work with key business /, Manage integrations /, Align on consumer /, Lead on the data
on = customers and align on with existing IT communication plan: needed for regulation
/, Introducing the data needs systemR what data, frequency complianceŒ
traceability program – , Handle user of updates, view for , Prioritize relevant
importance and how provisioning, security end userR regulation complianc K
you plan to rollouN assessments, , Align on Supplier 7, Finalize data sharing
,Coordinate supplier architecture reviewR disclosure plan: what format with regulators
trainin @ 7, Manage change tier of suppliers, what
7, Ensure supplier management requests dat
complianc K and implementations 7, Align on reporting
6, Decide the initial list of requirements and
supplierR data needs
2, Share supplier
feedback to solution
provider for
improvements

69
Define Your Program Roadmap for
Implementation 

This is the ultimate overview of your program to guide the implementation process. Ensure
that you have a clear roadmap for the first year in detail, as well as an idea of what comes
after that (balancing short-term action with long-term vision). Revisit the sample brand
roadmap on page 47, then download and fill in the blank template here.

By completing the blank templates in this toolkit, you will be on your way to building a
traceability program that is well-considered, robust and has the best chances of achieving
your ESG goals.

70
GLOSSARY

71
GLOSSARY

Decentralized Data: The process of attaching data to a

product, rather than the owner of a product, using
blockchain technology 

Digitization: The process of converting, streamlining and

API integration: Application programming interface are a converging analogue information from emails, PDFs and
set of protocols that allow different software systems to Excel spreadsheets into a digital format on a unified
share data 

system

Batch-level or Lot-level data: Granular information Due Diligence: The process of auditing your supply chain
pertaining to a defined quantity of a material or product to identify, mitigate, and account for potential
that is processed together 

environmental and social issues 

Bill of Material (BOM): A list of the raw materials and End to End visibility: The ability to track individual items
components, plus the quantities of each, needed to as they travel through the supply chain from raw materials
manufacture a product 

to their final destination

Blockchain: A digital ledger of transactions that is Enterprise Resource Planning (ERP): A software
duplicated and distributed across the entire network of system that allows brands to manage everyday business
computer systems 

operations like accounting, supply chain operations,

compliance and risk management 

Corporate Social Responsibility (CSR): A form of self-

regulation that businesses use to instigate philanthropic, Environmental, Social, and Corporate Governance
activist, or charitable initiatives whereby they engage in or (ESG): A​measurement that companies use to evaluate
support volunteering practices

the extent to which their operations impact three core

pillars of sustainability 

Certificate of Origin: Proof that a product was

manufactured in a specific country or region, used to Evidence request: The process of contacting suppliers,
comply with due diligence legislation 

either digitally or manually, to ask for information about

their operations in relation to a specific risk area 

Chain of Custody (CoC): As materials move through the

value chain, a Chain of Custody can be created by each Fiber Forward Traceability: The bottom-up process of
handler by recording critical information about the lot and tracing a product from the raw material phase to the end
its associated claims 

product in real-time 

Circularity: A model of production and consumption that Fragmentation: Data that has been broken up into
focuses on sharing, leasing, reusing, repairing, and different formats or across different platforms, leading to
recycling existing materials and products for as long as inefficiencies and inaccuracies 

possible 

Full package program with supplier: A sourcing model

Circular Economy: a system based on the principles of whereby the brand owns the design and works with T1
designing out waste and pollution by keeping materials suppliers, but purchases garments at a fixed cost from the
and products in use and regenerating natural systems.

garment manufacturer 

Cloud-based: Storing data through internet programs Full package production with agent: A sourcing model
rather than on central computers or networks

commonly used in fast fashion, whereby a brand

outsources the design, sourcing and production to
Compliance: Adhering to requirements that are decreed external agents

by laws and regulations 

Hard technology: Asset-intensive, physical, science-

Cut Make Trim: A sourcing model whereby the brand based technology, including innovations that integrate into
owns the design, sourcing and control of product existing production systems.
production

72
Product Backward Traceability: The process of tracking Supplier: Any actor within a supply chain that is involved
the supply chain of a product after it has been in the sourcing, manufacturing, or transportation of a
manufactured, otherwise known as top-down traceability 

material or product 

Product Lifecycle Management (PLM): Organizations Sustainable financing: The acquisition of financial
use this to develop new products, as well as track and resources to implement improvements to facilities with a
share data along the entire supply chain 

businesses supply chain 

Purchase Order (PO): A document issued by a brand to Third-party audits: Independent groups that perform on-
a supplier which indicates the styles, quantities, and the-ground assessments of facilities to ensure that they’re
prices for products they have purchased 

working in compliance with certifications 

Real-time data: Information that is collected about a Tier: Supply chains are commonly divided into tiers where
material or product, recorded as the item moves through different functions are performed to transform raw
the value chain 

material into a finished product 

Product Backward Traceability: The process of tracking Traceability: The ability to trace the history, application,
the supply chain of a product after it has been or location of a material or product through recorded
manufactured, otherwise known as top-down traceability 

identifications 

Product Lifecycle Management (PLM): Organizations Transparency: Relevant information that is available to
use this to develop new products, as well as track and all elements of the value chain in a standardized way,
share data along the entire supply chain 

which allows common understanding, accessibility, clarity

and comparison 

Purchase Order (PO): A document issued by a brand to

a supplier which indicates the styles, quantities, and Weight-based calculations: The measurement of a
prices for products they have purchased 

material or product by its weight in order to determine the

content makeup and instances of material wastage. 

Real-time data: Information that is collected about a

material or product, recorded as the item moves through
the value chain 

Request for Proposal (RFP): A document that

announces a company’s new initiative and solicits bids
from potential solution providers. A fashion brand will
produce an RFP to solicit proposals from traceability
solution providers.

Software as a Service 

Scalability: The ability to expand or increase the

implementation of a system or operation to a system-wide
level 

Soft technology: Digital B2C solutions like rental and

resale platforms, as well as B2B solutions like traceability
software 

Standardized data: The process of establishing common

identifiers so that multiple systems auditing different or
overlapping issues can exchange and collate information 

Sub Contracting: Employing people outside of your

organization to do work, either officially or unofficially

73