Sustainable cotton supply chain proponents Cotton Diaries are urging European Union policymakers to push for a more holistic traceability system.
The report, “Is Cotton Traceability Too Complex—or are We Just Mapping it Wrong?” argues that traceability’s key issue isn’t complexity but rather how the system is mapped. EU policymakers are currently finalizing discussions on the level of tier 4 supply chain scrutiny should be included in digital product passport regulations. Cotton Diaries said that Tier 4, which accounts for the farm level, has been described as too complex, but excluding it from traceability regulation would essentially institutionalize a blind spot.
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Cotton Diaries said that current supply chain maps fail to clearly account for the gin stage of cotton production, the crucial step when harvested cotton becomes fiber. The organization said this is the point where cotton transitions from agriculture to industry, and where origin data is already captured, but because the process does not neatly fit within existing tier structures, it remains unrecognized by traditional traceability models.
“Cotton isn’t too complex to trace—our current tools and models just aren’t adapted to how its supply chain actually works,” said Anne Oudard, Cotton Diaries sourcing and supply chain lead. “Recognizing ginning as a key stage for recording and transmitting origin data can finally make supply chains transparent, accountable and fair for both farmers and brands.”
In its report, Cotton Diaries argue that since cotton delivered to gins is already documented by volume, origin and supplier to organize payments and trade, this information could easily travel further down the supply chain with clear, mandatory flows. This leaves due diligence up to mostly voluntary investigation process, leaving environmental and human rights risks upstream insufficiently monitored.
Cotton Diaries has asked EU policymakers to recognize ginning as a distinct stage in cotton supply chain mapping, closing the gap between textile manufacturing and farmers. The organization also called for regulations that require transaction-based record keeping that captures origin information at the gin and ensures it is transmitted through the supply chain, rather than relying on retroactive traceability investigations.
“Traceability cannot remain a niche feature of certified supply chains,” Oudard said. “By recognizing ginning as a distinct stage and requiring transaction-based records, EU policymakers can ensure that due diligence relies on systematic information flows rather than voluntary investigation.”
Cotton Diaries said they believe this shift in traceability recording and verification will ensure that reliable origin information flows through the entire supply chain while creating enforceable due diligence. That will allow companies to systematically identify and address environmental and human rights risks upstream.
Ultimately, Oudard said this focus on the gin level will allow cotton supply chains to gain transparency, credibility and resilience, supporting responsible global sourcing. And it will allow initiatives such as the EU’s digital product passport program—which goes into effect next year for textiles—to make a greater impact on improving sustainability in the sector.
“Gins are the textile industry’s door into agriculture,” she said. “Once we map them clearly, the path upstream opens, making it possible to understand where cotton truly comes from and how it affects people and the environment.”
