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Why it matters

A new Wharton/NYU Stern study analyzed 100+ million U.S. maritime shipment records.

The finding is stark — 28% of all shipments have importer and supplier identities deliberately redacted from public view. The number has been climbing for a decade.

https://knowledge.wharton.upenn.edu/article/how-forced-labor-scrutiny-shapes-supply-chain-transparency/

TRUSTED BY FORTUNE 500 COMPANIES

The mechanism is shockingly easy.

A free, renewable request wipes your identity — and every supplier's — off the public record.

U.S. law requires CBP to make maritime shipment data public. But there's a carve-out: importers can file a free request — 30 minutes, almost never rejected — to scrub their identity and every supplier's identity from public records. Renewable indefinitely.

The program was designed to protect competitive information. Companies are using it to hide forced labor risk.

One trade compliance expert said it out loud after an NGO investigation triggered CBP action: "Redact what you can. Your brand is one manifest away from guilty by association."

The data tells you exactly where the hiding is happening.


Redaction spikes by industry, by region, and right after each enforcement event.

  • Apparel redaction rates approach 50%. Footwear clears it.
  • Eastern Asia, Southeast Asia, Northern Africa redaction rates far exceed the global average.
  • When DOL adds a country-commodity pair to its forced labor goods list, redaction rates in those supply chains jump 7.5 points within the same supply chain.
  • After the 2020 ASPI Uyghur report, cotton and apparel imports from China saw an 8-point surge in redaction share — and kept climbing through the UFLPA's enactment.

The researchers also found trade names heavily sourcing Chinese cotton and apparel before the scrutiny events were significantly more likely to vanish entirely from public records afterward — even if they kept importing.

What companies get wrong

Hiding delays discovery instead of fixing it — and visibility is becoming the real advantage.

The instinct to hide makes sense on the surface. Supply chains are complex. Audits miss things. Subcontractors exist four tiers down where nobody's looking.

But redaction doesn't fix the problem. It delays discovery while making the risk harder to manage.

CBP doesn't find forced labor on its own. The agency relies almost entirely on NGOs and investigative journalists who use shipment data to build cases and hand CBP actionable allegations. Redaction slows that process. It doesn't stop it.

And under UFLPA's rebuttable presumption: once your supply chain is flagged, the burden of proof is entirely yours. If you can't prove your goods are clean, they don't move.

The Wharton/NYU paper confirmed transparent supply chains give investors something to read. When you go dark, that signal disappears and your stock starts behaving like it has nothing to say.

The companies not hiding have a reason.

The researchers noted firms with robust due diligence are less likely to use manifest confidentiality. They don't need to hide. Their visibility is the point.

That's a measurable competitive advantage.

Not annual audit reports. Not supplier questionnaires sitting unanswered. Continuous, automated monitoring across every tier so when a customer, regulator, or investor asks show me your supply chain, you have an answer ready.

The companies building that capability now aren't just managing risk.

They're creating distance from everyone still betting opacity will protect them.

It won't.

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