US raises burden of proof on apparel supply chains

• New guidelines requires Sri Lankan exports to US maintain documentation tracing products to raw material sources
• Supplier declarations alone no longer sufficient to demonstrate compliance
• US buyers likely to seek greater visibility over cotton, yarn and fabric sourcing
• Development comes amid proposed 12.5% US duty on Sri Lankan exports under separate forced labour-related trade action

Sri Lanka’s apparel exporters face increased compliance demands from US buyers following new guidance issued by the United States Customs and Border Protection (CBP), which sets out stricter documentation and traceability requirements for goods entering the US market.

The guidance, issued under the US’s Uyghur Forced Labour Prevention Act (UFLPA), requires importers to maintain records tracing products back to the raw material stage and to demonstrate that goods do not contain prohibited inputs linked to forced labour.

While the UFLPA primarily targets products connected to China’s Xinjiang Uyghur Autonomous Region (XUAR), the latest guidance places greater emphasis on documentary evidence and supply chain traceability across the production process.

CBP states that importers should be able to provide records covering raw material sourcing, yarn production, fabric manufacturing, garment assembly, transportation and customs clearance.

The agency also notes that affidavits and supplier declarations alone are insufficient to establish compliance. Importers may instead be required to furnish purchase orders, invoices, production records, bills of lading, payment records and other commercial documentation generated during the normal course of business.

The guidance is expected to increase information requests from US brands and retailers to overseas suppliers, including apparel manufacturers in Sri Lanka.

Industry sources said buyers are likely to seek more detailed information on cotton origin, yarn suppliers, fabric mills, subcontractors and production records as part of supplier compliance programmes.

CBP also encourages the use of origin-verification techniques, including isotopic testing, where questions arise regarding the provenance of raw materials.

The apparel sector remains one of the industries most exposed to enhanced scrutiny due to the complexity of global textile supply chains and the extensive use of multi-country sourcing arrangements.

The latest guidance comes at a time when Sri Lanka is also facing increased scrutiny from US trade authorities.

Earlier this month, the Office of the United States Trade Representative (USTR) proposed placing Sri Lanka in the higher 12.5% tier of a new duty regime targeting economies deemed to have failed to impose or effectively enforce prohibitions on imports produced using forced labour.

The proposal followed a Section 301 investigation, with the USTR concluding that Sri Lanka’s policies and practices relating to forced labour imports burdened or restricted US commerce.

The US remains Sri Lanka’s largest single export market, accounting for around 22% of merchandise exports. Exports to the market declined 3.15% year-on-year to $ 196.37 million in April, while cumulative exports during the first four months of 2026 fell 2.09% to $ 945.76 million.

Apparel remains Sri Lanka’s largest export industry, accounting for close to 40% of merchandise export earnings and generating more than $ 4 billion annually.

The latest CBP guidance indicates that access to the US market will increasingly depend on the ability of exporters and their suppliers to provide detailed evidence on sourcing and production practices throughout the supply chain.