A September 3 oversight letter asks DHS about textiles, importer evidence, transshipment, and AI-assisted origin checks. Apparel companies should read it as a signal to test their cotton records—not as a new rule or proof about any shipment.
A purchase order cannot prove an entire supply chain, but it can create the identifiers, evidence requests, and change controls that make later tracing possible.
Onboarding is a versioned evidence process covering identity, ownership, facilities, capability, subcontracting, labor, safety, quality, traceability, trade, data access, incidents, contracts, and ongoing review—not a one-time score.
AI can collect and route dated risk signals, but it must preserve provenance, separate entities, invite correction, protect workers, and keep procurement and rights decisions with qualified people.
AI can organize a sourcing search, but a match is only research-ready when criteria, dated evidence, risk review, direct verification, ownership, and disqualifying facts remain visible.