What has changed since the UFLPA was implemented?
The biggest shift we've seen over the past three years is that “If you claim it, can you prove it?” is no longer a rhetorical question—it’s a legal and operational necessity. Brands and manufacturers, especially those importing into the U.S., are under increasing pressure to substantiate their claims of origin — not just for cotton, but for any product that could have a nexus to a high‑risk region.
For cotton specifically, the challenge lies in the fact that all cotton looks the same. You cannot tell origin by sight, and paper‑based documentation can be easily manipulated and unreliable as the single source of truth. That’s why physical verification — using forensic science and isotopic analysis — has become essential. These tools help brands prove not only where their cotton comes from, but critically, where it does not. Since the UFLPA took effect on June 21, 2022, it’s not just about the point of origin — it’s also about where that cotton goes and where it ends up. That is why we are seeing physical verification increasingly paired with digital traceability platforms to create a defensible chain of custody.
While many brands have enhanced compliance, others exploited the de minimis loophole — platforms like Shein and Temu shipped low‑value parcels (<$800) from China/Hong Kong without duties or formal customs entry. That ended with Executive Order 14256: effective May 2, 2025, all shipments from China and Hong Kong — regardless of value — now require formal customs entry and are subject to duties. CBP has also introduced proposed rules to tighten this further: goods under Section 232/201/301 tariffs are ineligible for de minimis; 10‑digit HTSUS codes are required; and if daily shipments exceed $800 in aggregate, none qualify for exemption.
These measures close significant loopholes. Still, consistent enforcement remains vital: any discrepancies in compliance risk undermining the law’s intent and eroding consumer trust.
At GenuTrace, we're working with responsible brands, manufacturers, and growers to close that trust gap—providing scientific, data‑backed proof of origin and helping clients build the kind of traceable supply chains that hold up under regulatory and consumer scrutiny.
