Why Manufacturers Kept Stockpiling After Their Tariffs Got Struck Down

Why Manufacturers Kept Stockpiling After Their Tariffs Got Struck Down

Supply Chain Analytics Pulse

Why Manufacturers Kept Stockpiling After Their Tariffs Got Struck Down

September 2026 | Supply Chain Analytics Pulse

In February 2026, the Supreme Court struck down the legal authority behind most of the tariffs that had pushed U.S. manufacturers into their biggest inventory buildup in a decade. The tariffs were gone within days. The stockpiling was not.

Four months later, GEP’s Global Supply Chain Volatility Index, which tracks tens of thousands of businesses each month, found manufacturers building safety stock at the highest level since January 2023. Shortages of critical inputs hit their highest level since late 2022.

Meanwhile, U.S. factories just posted their strongest month of production since 2021, and the index tracking how “too low” customers’ inventories are sits near a multi-year extreme. A replenishment cycle is forming at exactly the moment safety stock strategy needs to get smarter, not just bigger.

01 Eighteen Months of Tariff Whiplash

The 2025 Buildup

Through 2025, U.S. manufacturers front-loaded raw materials and components like never before. Durable-goods “materials and supplies” inventories hit roughly $221 billion by April, up 3.9% year over year, and total durable-goods inventories climbed for ten straight months, to about $591 billion by July.

Trade uncertainty drove it. NAM’s Outlook Survey found it was manufacturers’ top business challenge all year, cited by 76.2% in Q1 and 73.1% in Q4. By year’s end, 80.3% had paid tariffs on imported inputs, and the Hackett Group put a price on the caution: $1.7 trillion trapped in excess working capital across the 1,000 largest U.S. public companies.

$221B

inventories by April

$591B

inventories by July

$1.7T

trapped in excess working capital

Through 2025, U.S. manufacturers front-loaded raw materials and components like never before. Durable-goods “materials and supplies” inventories hit roughly $221 billion by April, up 3.9% year over year, and total durable-goods inventories climbed for ten straight months, to about $591 billion by July.

NAM respondents expected the buildup to ease slightly, about 0.2%, over the next year. The stockpiling wave, it seemed, had peaked.

The reversal nobody de-stocked for

On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that IEEPA does not authorize the president to impose tariffs, striking down the “Liberation Day” and reciprocal tariffs behind most of 2025’s front-loading. Collection stopped four days later. Refunds are still working through the Court of International Trade.

What replaced IEEPA moved just as fast:

February 20, 2026 Hours after the ruling, the administration invoked Section 122 of the Trade Act of 1974 for a new global surcharge, 10% rising to the statutory maximum of 15% within two days.
July 24, 2026 Section 122 hit its 150-day statutory limit and expired, with no extension from Congress. New Section 301 tariffs took effect the same minute, covering 60 economies and roughly 99.4% of U.S. imports at 10% or 12.5%. The EU stayed at its own 15% trade-deal ceiling.
Through August 2026 Country-specific add-ons kept arriving, including new duties on Canadian and Brazilian goods.

Section 232 tariffs on steel, aluminum, and copper run on separate legal footing and were untouched by the ruling; they remain at 50% on covered articles. What changed, effective April 6, 2026, was scope: many derivative products, parts and components made from those metals, moved to a flat 25% duty on full import value instead of just the metal content, quietly widening exposure for metal-intensive manufacturers.

The data did not cooperate with the “hangover” prediction

Here’s what the original 2025 forecast expected: demand cools, shelves stay full, and 2026 becomes a quiet year of working through last year’s buying. That’s not what happened.

Materials-and-supplies inventories reached $225.5 billion in January 2026, still above where they stood in April 2025. Total durable-goods inventories kept climbing too, up nine straight months to $602.0 billion by June. GEP’s June figures told the same story from the buying side: safety stockpiling back at its highest level since January 2023.

Demand didn’t cooperate either. The ISM Manufacturing PMI hit 55.6% in July, the best reading in four years, while the index tracking customers’ inventories sank to 40.7, deep in “too low” territory.

$225.5B

materials and supplies inventories by January 2026

$602B

durable-goods inventories by June

Put those two trends together and the picture isn’t a hangover. It’s a restocking cycle arriving on top of a warehouse that never actually emptied.

02 What “Segment and Go Dynamic” Actually Delivers: A $9.3M Proof Point

Segment inventory first and make safety stock dynamic rather than static, is not a theoretical improvement. MIT’s Center for Transportation and Logistics ran the numbers on a real network, and they are large enough to change how a safety stock budget gets built.

The sponsor was a U.S. grocery retailer running a hub-and-spoke distribution network that was, by its own admission, missing the mark despite carrying plenty of stock: 57 days of supply for dry food, low inventory turnover, and service levels that still varied widely from node to node. As the business had expanded and SKU counts multiplied, a traditional inventory policy, one set of rules applied network-wide, had stopped working.

Researchers Vi Duong and Nic Holwerda, supervised by Dr. Eva Ponce, modeled 61 SKUs across 31 nodes using a commercial multi-echelon inventory-optimization platform, running 18 scenarios that combined six update frequencies with three service-level targets. Published through Supply Chain Management Review in March 2026, it’s one of the more concrete proof points available for what dynamic, segmented safety stock actually returns:

63%

max inventory value reduction, 61 SKUs

$9.3M

annual savings on just those SKUs

40%

working capital cut from annual updates

50%+

savings from hub-level nodes

High-variability products benefited the most from frequent updates. Stable, low-variability SKUs saw little additional gain from updating more often than biannually: the highest-value move wasn’t updating everything weekly, it was segmenting products by variability and matching update frequency to each segment.

That last point maps directly onto how tariff-exposed inventory should be triaged. The SKUs and inputs worth a dynamic, frequently recalculated safety stock policy are not the highest-volume ones by default. They are the ones with genuine demand or supply volatility, which, in 2026, increasingly means anything touched by a tariff schedule with a defined expiration date, a single-sourced input, or a lane running through a contested shipping corridor.

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03 Two Sectors, Two Strategies: Automotive’s Live Split Test

Detroit’s three largest automakers spent the first half of 2026 absorbing the same tariff and input-cost environment and arrived at two different buffer strategies, in real time, one of the clearest live comparisons available for how the same volatility produces different inventory decisions depending on where a company’s actual exposure sits.

AutomotiveBuffered

Buffered Against a Single Point of Failure

Ford’s aluminum supply has been constrained for months by fires at facilities owned by Novelis, a key supplier. The company is now facing roughly $2 billion in commodity headwinds this year tied to higher aluminum prices from that disruption, on top of a separate, roughly $1 billion exposure to tariffs that remained in force even after Ford’s projected $1.3 billion refund on invalidated IEEPA levies.

$2B

aluminium commodity headwind

$1.3B

projected IEEPA refund

$1B

trariffs still in force

The lesson is not that Ford guessed wrong on tariffs. It’s that aluminum, a high-commodity-content input Ford sources heavily and cannot easily substitute, was already the kind of item worth elevated, not blanket, safety stock, and a supplier fire proved the point independently of anything trade policy did.

AutomotiveLean

Betting on Lean insted of Buffered

GM took the opposite approach, describing its strategy explicitly as keeping inventory “lean” to preserve agility: 516,000 units on hand in the first quarter of 2026, a full-year tariff cost estimate revised down to $2.5–3.5 billion, from an original $3.0–4.0 billion, and a roughly $500 million refund of its own forecast.

$516K

units on hand, Q1 2026

$2.5-3.5B

revised tariff cost estimate

$500M

refund forecast

Leaner inventory carries more stockout risk if demand or supply moves suddenly. But for parts and platforms that are not concentrated in a single tariff-exposed input, it also frees working capital that a buffer strategy would otherwise tie up.

04 Safety Stock Readiness Check

Before adding a single unit of buffer inventory, it’s worth an honest look at whether the organization can actually target that buffer, or whether it’s about to repeat the blanket-stockpiling pattern that trapped $1.7 trillion in working capital industrywide. 

DimensionEarly StageDevelopingAdvanced
Tariff & Single-Source Exposure MappingNo formal mapping of which SKUs or inputs are tariff-exposed or single-sourced. Decisions follow instinct or the last disruption, not a live score.Exposure tracked for top suppliers and commodities, refreshed after major policy changes rather than continuously.Every SKU or input carries a live tariff-exposure and single-source risk score that feeds directly into ABC/XYZ segmentation and buffer eligibility.
Safety Stock Policy DesignFixed levels set once and rarely revisited. One formula applied network-wide regardless of demand variability.Recalculated on a fixed annual or semi-annual cycle. Some segmentation by volume exists, but not by variability.Recalculated on a cadence matched to each segment's volatility, quarterly or better for high-variance items, biannual for stable ones, not a calendar default.
Working Capital GovernanceInventory increases approved ad hoc, with no visibility into carrying cost or the specific risk being hedged.Buffer inventory has an approval process and is reported, but carrying cost is not weighed against a quantified disruption-avoidance value.Buffer inventory is funded and reported as a risk-management line item with an explicit reassessment date and a modeled write-down exposure if demand shifts.
Regional Policy DifferentiationOne global inventory policy applied to every region and business unit.Regional teams can request exceptions, but there is no structural difference by default.Inventory and buffer policy differ deliberately by region, reflecting each region's actual demand and trade-policy conditions rather than a single template.
Reversal / Destock Signal MonitoringNo defined trigger for reducing stock. Teams learn demand has shifted when a write-down appears in quarterly results.Basic inventory-to-sales and days-of-supply metrics are tracked monthly, without a defined action threshold.A named owner monitors leading indicators (inventory-to-sales ratio, new orders, downstream customer inventory indices) against a defined trigger, with authority to act before the write-down stage.

05 Key Implementation Steps: Choose Your Perspective

Click on the perspective you want to analyze – executives or analysts.

Analyst View

Build a Combined Tariff and Single-Source Exposure Score, Then Re-Rank Your ABC Segmentation

Flag anything scoring high on all three for buffer eligibility, regardless of its existing volume classification.

Re-run the score whenever a tariff authority changes, since the underlying exposure can shift within days.

Combine landed-cost tariff sensitivity, supplier concentration, and lead-time variance into a single score per SKU or input.

Replace Calendar-Based Safety Stock Reviews With a Volatility-Based Cadence

Apply MIT CTL’s finding directly: segment by demand and supply variability, and match update frequency to the segment rather than the calendar.

Model the expected value of moving from annual to biannual updates before recommending anything more frequent.

Prioritize hub-level or upstream nodes first. In the MIT case, more than half of total savings came from correcting overstocking at hubs.

Track the Tariff and Legal Calendar as a Supply Signal

Maintain a simple tracker of tariff-authority expiration dates, pending court rulings, and Section 301/232 actions, feeding directly into the landed-cost model.

Treat each known expiration date as a planning trigger to re-run exposure scores in advance, not a surprise to react to afterward.

Where refunds are pending, track them as a working-capital recovery item, not just a customs footnote.

 

Watch Downstream Inventory Indices as a Leading Demand Signal

Monitor ISM’s Customers’ Inventories Index and Backlog of Orders Index alongside internal forecasts.

Cross-reference against GEP’s monthly volatility data for regional divergence.

Build the trigger for scaling safety stock up, not just down, since current data points toward a demand-driven restocking cycle forming on top of already-elevated upstream inventory.

Executive View

Require a Tariff-Exposure Segmentation Before Approving Any Blanket Buffer Increase

Score inputs and SKUs on tariff exposure, single-source concentration, and lead-time variability, not on which category asked loudest for more stock.

Reserve elevated safety stock budget for the resulting top tier only. If a request can’t name the specific SKUs it covers, it isn’t ready for approval.

Treat Ford’s aluminum exposure and GM’s lean parts strategy as the same lesson from two directions: the input’s actual risk profile should decide the policy, not company-wide habit. 

Separate the Working Capital Conversation From the Resilience Conversation

Fund buffer inventory as an explicit risk-management line, with a stated ROI against a named disruption, rather than folding it into the general inventory budget.

Ask what write-down risk arises if the demand or policy assumption behind a buffer reverses. 

Weigh any new buffer request against the $1.7 trillion already sitting in excess working capital industrywide. More stock is not automatically more resilience.

Put a Named Owner on the Reversal Signal

Define the specific trigger, for example a rising inventory-to-sales ratio alongside falling new orders, that would mean it’s time to de-stock, before the buffer is built.

Assign that trigger to one person with the authority to act on it, not a committee that reviews it quarterly.

Revisit the trigger whenever tariff authority itself changes, since a policy reversal can move the underlying risk faster than a normal planning cycle would catch.

Localize Policy by Region

Don’t import a U.S. buffer playbook into Europe or Asia. GEP’s own regional data shows North American and Asian manufacturers building inventory through mid-2026 while European manufacturers were still working through excess stock.

Require regional teams to justify their inventory policy against their own trade-policy and demand conditions, not against head office’s stock.

Build in a standing review point tied to major trade-policy dates rather than a fixed calendar quarter.

06 Conclusion

The last eighteen months did not validate or discredit the manufacturers who built safety stock through 2025. It discredited the idea that safety stock built to hedge one specific policy risk will still make sense once that policy changes, because in 2026, policy changed faster than most inventory plans do.

What held up across that whiplash was not a bigger buffer. It was a better-targeted one. Buffer inventory earns its cost when it’s aimed at something genuinely concentrated, volatile, and hard to substitute. It’s just tied-up cash everywhere else.

The restocking cycle now forming, with customer inventories near multi-year lows and factory output at a four-year high, is the next test of that discipline. It will reward the organizations that already know which SKUs deserve the buffer, and it will quietly cost the ones still deciding that with a blanket policy and a calendar reminder.

In case you missed it – Previous Pulse Editions

The New Cost of Picking the Wrong Carrier

The New Cost of Picking the Wrong Carrier

Supply Chain Analytics Pulse

The New Cost of Picking the Wrong Carrier

August 2026 | Supply Chain Analytics Pulse

In June 2026, the average U.S. dry van spot rate did something it hadn’t done since February 2022: it rose above the contract rate. Tender rejections hit 17.55%, the highest level in four years.

Three weeks earlier, the U.S. Supreme Court had ruled  that freight brokers can be sued under state law for carelessly choosing an unsafe carrier. And across the industry, fraud investigators were closing out 2025 with cargo-crime losses near $725 million, up 60% year over year.

None of these three developments made headlines together. But put next to each other, they describe the same moment from three different angles: the decision of which carrier to use just got harder to make well, and more expensive to make badly.

01 Three Forces, One Decision

Capacity is turning for the first time in years

From 2022 through most of 2025, trucking capacity ran well ahead of freight demand. Carrier counts had ballooned during the pandemic-era boom, and the resulting oversupply pushed rates down for nearly four straight years, the longest freight recession most shippers had ever managed through. That gave buyers enormous leverage: if one carrier’s price or terms weren’t ideal, ten more were waiting.

That leverage is disappearing. According to DAT Freight & Analytics, the national average dry van spot rate crossed above the contract rate in June 2026 for the first time since February 2022, with spot rates briefly touching $3.83 per mile. Ryder and FreightWaves’ June State of Transportation report put tender rejection rates above 15%. Reefer and flatbed segments show the same pattern.

The mechanics matter here: when carriers can earn more chasing spot loads than honoring contracted rates, they reject contracted tenders. Shippers scramble to fill the gap, often with whichever carrier is available on short notice.

The legal shield brokers relied on just narrowed

On May 14, 2026, the U.S. Supreme Court issued a unanimous decision in Montgomery v. Caribe Transport II, LLC, holding that a federal transportation law does not automatically shield brokers from state negligent-selection lawsuits when a carrier they chose turns out to be unsafe. To be precise about what that does and doesn’t mean: the Court didn’t rule on anyone’s guilt, it removed a procedural defense that used to get these claims dismissed early, before discovery. The practical effect is that negligent-selection claims against brokers are now harder to dismiss nationwide, and legal commentary suggests the same reasoning could plausibly extend to other intermediaries that select carriers, including 3PLs and digital freight-matching platforms, though that hasn’t yet been tested in court.

Fraud is rising exactly when vetting is hardest to do carefully

The third force is less visible in boardrooms but well documented in industry data. According to Verisk CargoNet, U.S. supply chain crime losses reached roughly $725 million in 2025, up 60% from 2024, with the average loss per incident climbing to $273,990. CargoNet separately reports that “strategic theft”, fraud and identity-based schemes, as opposed to physical break-ins has risen roughly 1,500% since 2021.

Licensed freight broker based in San Antonio, had its identity stolen by overseas criminals who spoofed its email domain and logo, then brokered real loads to unsuspecting carriers under their name. One six-figure shipment of energy drinks was rerouted more than a thousand miles before anyone realized the company that had booked it wasn’t real. The fraudulent entity was even added to the FMCSA’s public SAFER safety-rating database alongside the legitimate one, and owner Adam Blanchard testified that getting it removed proved difficult.

Buyers hold contracts, and audit rights, with their Tier 1 suppliers. Almost none of that formal standing extends to Tier 2 or Tier 3. A visibility platform has nothing to connect to below the purchase order boundary, because the purchase order boundary is exactly where the enrolled, contracted relationship ends.

02 What the Research Shows

On detection performance

May 2026 study by Hayes and colleagues, published via a machine learning and behavioral analytics framework for supply chain fraud, combined graph neural networks with behavioral pattern analysis and reported 0.94 precision and 0.91 recall in identifying fraudulent transactions, a 34% reduction in false positives compared to standalone models. Notably, the behavioral component surfaced collusive fraud rings involving shell vendors and inflated invoicing that traditional rule-based checks had missed entirely. Pattern-based models that update continuously can catch coordinated fraud that this kind of one-time check will never see, simply because they keep watching after the initial check is done.

94%

precision in fraud detection

91%

recall in indetifying fraud

34%

reduction in false positive flags

On legal treatment of automated decisions

The law is moving faster than many logistics organizations may have registered. California’s AB 316, effective January 1, 2026, prohibits a company from defending itself by arguing that an AI system “autonomously” caused the harm: a company that deploys, modifies, or uses an AI tool cannot point to the tool as the responsible party. A June 2026 analysis in the Berkeley Technology Law Journal goes further, arguing that liability frameworks built around a single AI system don’t hold up well once multiple AI agents interact, for instance, a shipper’s procurement agent negotiating with a carrier’s booking agent, because those handoffs are typically unlogged and difficult to reconstruct after something goes wrong. NIST’s AI Agent Standards Initiative, launched in February 2026, has identified agent identity and traceability as a priority precisely because of this gap. A useful, non-freight precedent is Mobley v. Workday, in which a plaintiff argued that an employer couldn’t avoid discrimination liability simply because an algorithm made the screening decision; courts have shown little appetite for treating “the algorithm decided” as a standalone defense.

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03 How the Industry is Responding

Two proof points and one cautionary tale — chosen because they span three different sub-tier verification methods and three different outcomes.

BrokageAI Automations

C. H. Robinson: Automating the Decision the Courts are Scrutinizing

C.H. Robinson occupies an unusual position in this story: it’s the named broker in Montgomery, and simultaneously one of the industry’s most visible adopters of AI in the exact decision the case is about. The company has deployed more than 30 AI agents handling over 3 million shipment-related tasks through what it calls its Always-On Logistics Planner, and its AI truckload optimization product explicitly folds carrier selection into a continuous decision engine, evaluating carrier performance, lane conditions, and market dynamics on an ongoing basis rather than relying on a static routing guide.

Whatever the outcome of the underlying litigation, the pairing is instructive: the same organization facing the industry’s clearest signal that carrier selection now carries real legal exposure is also betting that continuous, data-driven selection is the better way to make that decision.

30+

deployed AI agents

3M

shipment related tasks handled

3PLHuman-AI Balance

DHL Supply Chain: Free People for the Judgement Calls

At the Manifest 2026 conference, DHL Supply Chain’s VP of integrated transportation described a more incremental path: AI agents now handle appointment scheduling and much of exception management, which frees experienced staff to focus on the calls that genuinely require judgment. It’s a useful counterpoint to the “full automation” narrative: DHL’s public framing treats AI as a way to protect human attention for higher-stakes decisions, not replace the decision-maker.

ComplianceRisk Tooling

A Vetting-Technology Sector has Emerged Specifically for this Problem

A cluster of companies now exists to solve exactly the gap this edition describes: continuous, defensible carrier verification rather than one-time onboarding checks. Highway’s carrier-identity platform reportedly blocked around 2 million fraudulent emails in 2025, up 117% year over year, along with 8.5 million spoofed phone numbers. Other platforms, including Carrier Assure, Descartes’ MyCarrierPortal, and various RMIS providers, continuously monitor FMCSA safety data, insurance status, and identity signals rather than checking them once at onboarding and assuming they hold.

2M

fraudulend emails in 2025

117%

increas year over year

8.5M

spoofed phone numbers

04 Organizational Readiness Check

If most of your answers sit in Levels 1–2, the current market conditions (tight capacity, active fraud, sharpened legal exposure) describe real risk sitting inside a normal-looking process, not a hypothetical one.

DimensionLevel 1 — Ad HocLevel 2 — DevelopingLevel 3 — ManagedLevel 4 — Defensible
Safety data checksChecked informally, if at all, at onboardingChecked once at onboarding via FMCSA lookupRe-checked periodically (e.g., quarterly)Continuously monitored with automated alerts on rating changes
Identity verificationAssumed legitimate based on paperwork receivedManual verification of MC/DOT number onlyCross-checked against multiple identity signalsContinuous identity monitoring integrated into tender workflow
Documentation trailNo record of why a carrier was chosenRate and availability recorded, rationale notSelection rationale recorded inconsistentlyEvery selection decision timestamped and auditable
OwnershipNo one owns carrier-selection risk explicitlySits informally with procurement or dispatchNamed owner exists but no formal escalation pathClear governance with defined executive accountability
AI/automation oversightNo automation in carrier selectionAutomation exists but undocumented decision logicAutomated recommendations, human sign-off requiredFull audit trail of automated decisions, human-in-the-loop on exceptions

05 What to do Next: Choose Your Perspective

Click on the perspective you want to analyze – executives or analysts.

Analyst View

Build a carrier risk score that sits next to your rate comparison, not separate from it.

If your team already runs cost comparisons across LSPs during tenders, the safety and fraud-risk profile of each carrier belongs in the same view, updated on the same cadence.

Move from point-in-time to continuous monitoring.

A carrier’s FMCSA safety rating, insurance status, and identity signals can all change between onboarding and the tenth load you give them. is.

Start logging selection rationale, not just selection outcomes.

A simple timestamped note (why this carrier, based on what data, at what point) creates a documentation trail that a purely automated system needs just as much as a human decision-maker does.

Map what AI can decide alone versus what needs human sign-off.

If AI or automation already influences carrier selection, document that boundary explicitly rather than leaving it assumed.

Executive View

Assign explicit ownership of carrier-selection risk.

In many organizations, this decision is made thousands of times a week with no formal risk-governance layer above it.

Revisit insurance coverage assumptions.

The FAAAA sets minimum insurance requirements for carriers but not for brokers or 3PLs; confirm your coverage reflects the post-Montgomery landscape.

Treat AI-assisted procurement as a governance question, not just an efficiency one.

Confirm there’s a human checkpoint before a new or unfamiliar carrier is used for the first time.

Budget for the capacity shift, not just the liability shift.

Tender rejection rates at four-year highs mean carrier options are narrowing at the exact moment rigor is most needed.

06 Conclusion

None of these three forces created the others. But they’re now converging on a single, frequently repeated decision that most organizations have treated as low-stakes for a long time: which carrier gets the load. The tools to make that decision more rigorously already exist.

The question this edition leaves for your team isn’t whether to adopt them, but whether your organization can currently produce a clear, timestamped answer to a simple question: for the last carrier your team selected, why that one, and based on what?

In case you missed it – Previous Pulse Editions

Most Supply Chains Still Go Dark Below Tier 1

Most Supply Chains Still Go Dark Below Tier 1

Supply Chain Analytics Pulse

Most Supply Chains Still Go Dark Below Tier 1

August 2026 | Supply Chain Analytics Pulse

A decade-old 6% statistic still gets recycled as current research. The real numbers are different, and the gap between what executives believe and what they can actually verify is the more useful numbers for a board conversation.

The claim that only 6% of companies have full end-to-end supply chain visibility traces back to the GEODIS Supply Chain Worldwide Survey, a poll of 623 companies conducted in 2017. Nearly a decade later, that same 6% figure is still being presented as fresh 2026 data across dozens of procurement and logistics roundups.

More recent, purpose-built surveys put genuine end-to-end visibility somewhere between 13% and 18%. QIMA’s 2026 Global Sourcing Survey found 18% of companies report full end-to-end visibility, an improvement on prior years, though the same survey found average supplier-network mapping sits at only 60%, meaning a large share of companies that have mapped their network still don’t have verified visibility into it. Achilles’ Global Supplier Risk and Sustainability Survey found only 6% of organizations have full visibility specifically into Tier 2 and Tier 3 suppliers, and EcoVadis’s Sustainable Procurement Barometer found only 12% can monitor more than half of their Tier 2 base at all.

The pattern holds regardless of who ran the survey or how “full visibility” was defined: visibility is high at Tier 1 and collapses sharply beyond it. McKinsey’s 2025 supply chain risk research found 95% of leaders report visibility into Tier 1 risk, while only 42% of the same group report visibility into Tier 2 or beyond. Executive confidence in overall visibility runs as high as 93% in some surveys, even as the same executives name Tier 2 and Tier 3 suppliers as their single biggest blind spot. That confidence-capability gap, not any single percentage, is the more useful number for a board conversation: dashboards built on Tier 1 completeness are routinely mistaken for full-chain visibility.

01 Why Technology Alone Hasn’t Closed the Gap

Five structural forces explain why more AI and more dashboards haven’t moved the needle much on their own.

Buyers hold contracts, and audit rights, with their Tier 1 suppliers. Almost none of that formal standing extends to Tier 2 or Tier 3. A visibility platform has nothing to connect to below the purchase order boundary, because the purchase order boundary is exactly where the enrolled, contracted relationship ends.

Tier 1 suppliers frequently treat their own upstream relationships as proprietary information and decline to disclose them, and in plenty of cases only have partial visibility into their own exposure further upstream anyway. Meanwhile a meaningful share of sub-tier suppliers, more than a third by some counts, have no plans to adopt any AI or digital reporting tools at all, leaving buyer-side systems with nothing compatible to connect to on the supplier’s side even where the will to share data exists.

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Roughly half of organizations attempting to unify visibility platforms across a fragmented IT landscape cite integration complexity and data quality as the primary blockers, and a majority say legacy systems continue to blunt the return on newer AI and visibility tools. Where sub-tier data does exist, it tends to be self-reported at onboarding and rarely refreshed, meaning the further a supplier sits from the direct contract, the older and less trustworthy its data typically is.

High executive confidence coexists with low actual capability because most organizations’ sense of “visibility” is really a sense of Tier 1 completeness. Nobody sets out to conflate the two; it happens because Tier 1 is where the contracts, the data feeds, and the dashboards all live.

And increasingly, it is a regulatory problem. The EU’s Corporate Sustainability Due Diligence Directive, the US Uyghur Forced Labor Prevention Act, and Scope 3 emissions disclosure rules now legally require sub-tier evidence, not just Tier 1 attestations.

02 Three Methods Actually Closing the Sub-Tier Gap

None of these approaches are new in concept, but each has moved from pilot to production use over the past two to three years in ways that don’t show up in a typical visibility software comparison article.

Trade-data network inference

Rather than waiting for a Tier 1 supplier to voluntarily disclose its own upstream relationships, this approach reconstructs the supplier network directly from customs and bill-of-lading records, information that governments already require at the border regardless of whether any individual company wants to share it. Platforms built on this model, S&P Global’s Panjiva being the largest, now index billions of shipment records and millions of companies across roughly twenty countries, and use network analysis to surface buyer-supplier relationships that would otherwise stay invisible. The method has a real limit worth naming: it shows trade flows and corporate relationships, not labor conditions or compliance status. It is a mapping layer, useful for finding out who is actually connected to whom, not a verification layer that confirms a supplier is behaving responsibly.

Forensic and isotopic origin verification

This addresses a different failure mode: paper trails that are technically complete but unreliable, whether through honest error, transshipment, blending, or deliberate falsification. The method analyzes naturally occurring chemical and isotopic variations in a raw material itself, shaped by the soil, water, and climate where it grew or was mined, and compares that chemical fingerprint against a reference database of known origins. Because the test examines the physical material rather than accompanying documents, it produces evidence that doesn’t depend on a supplier’s paperwork being honest. US Customs and Border Protection has explicitly recognized isotopic testing as admissible evidence for forced-labor compliance and began expanding its own in-house testing capability for exactly this reason.

Blockchain-based material passports

This method tackles the standardization and incentive problems directly, giving multiple parties in a value chain — miner, refiner, component maker, assembler — a shared, tamper-evident ledger to record material provenance, emissions, and recycled content as materials change hands. Rather than asking each sub-tier supplier to disclose data into a buyer’s proprietary system with no benefit to the supplier, a shared passport standard gives every participant in the consortium the same verified record, which is part of why these programs have found more sub-tier cooperation than bilateral disclosure requests typically do. The EU’s Digital Product Passport framework, starting with batteries, is effectively forcing this approach into a common data schema across the industry rather than leaving it to each company to build its own.

03 Case Studies

Two proof points and one cautionary tale — chosen because they span three different sub-tier verification methods and three different outcomes.

AutomotiveBlockchain Material Passport

Tracing Critical Minerals From Rock to Car

Volvo Cars and UK-based traceability provider Circulor began working together in 2018 on a problem that sits at the center of the visibility gap: cobalt, nickel, lithium, and graphite pass through mining, refining, and component manufacturing steps that are almost never contractually connected to the automaker buying the finished battery. Six years later, in 2024, Volvo’s EX90 became the first commercially available vehicle to ship with a working digital battery passport, built on Circulor’s platform, tracing critical raw materials from extraction through to the finished battery pack.

The passport records three things that matter to a regulator and a customer differently: the origin and production journey of each critical raw material, the embedded carbon footprint of the full battery pack, and the percentage of recycled content used. The mechanism that made supplier participation possible was not a mandate from Volvo alone — it was membership in the Global Battery Alliance, a multi-party consortium that gave sub-tier suppliers a shared, reusable record instead of a one-off disclosure requirement unique to a single customer.

Under the EU Battery Regulation, digital battery passports become mandatory for EV and large industrial batteries from February 18, 2027, and due diligence obligations covering cobalt, lithium, nickel, and natural graphite apply from August 18, 2027.

6 yrs

from first pilot (2018) to commercial rollout (2024)

145+

suppliers connected across the battery value chain

Feb / Aug ’27

EU passport & due diligence deadlines

ApparelForensic Origin Verification

When the Paper Trail and the Physical Material Disagree

Cone Denim, the denim manufacturer owned by Elevate Textiles, is one of the most established named users of Oritain’s forensic cotton verification, using the science to certify to its own retail customers that specific denim rolls were made from cotton grown in the countries claimed, and not from regions flagged under forced-labor rules. The value to Cone Denim’s customers is that the result is independent of any document Cone Denim itself could produce.

Drawn from five years of testing roughly 1,000 garments annually across 40 brands, the data found that while 94% of UK companies and 87% of US companies surveyed said they trace their cotton supply chains, 90% of the brands actually tested in 2025 returned at least one result consistent with prohibited cotton exposure, up sharply from 64% the year before. Oritain’s own leadership has described this as a widening “verification gap” between documentation and reality.

The broader lesson for any Tier 2/3 raw-material category, not just cotton, is that self-reported traceability and verified traceability are two different claims, and only one of them holds up when a regulator asks for evidence rather than a supplier’s word.

96%+

of global cotton production covered by Oritain’s reference database

90%

of brands tested in 2025 returned a prohibited-origin result, up from 64%

94%/87%

of UK / US companies believe their cotton supply chain is traced

SolarUFLPA Enforcement Exposure

What the Blind Spot Costs When Customs Finds It First

Not every case is a success story, and that is the point of including one that isn’t. VSUN, a solar module brand acquired by Japanese manufacturer Toyo in September 2025, had modules detained by US Customs and Border Protection in early 2026 under the Uyghur Forced Labor Prevention Act. Industry analysts tied the detentions to solar cells most likely produced at VSUN’s Ethiopia facility, coinciding with a broader spike in CBP detentions of Ethiopian-origin solar cells and components in January and February 2026. Analyst estimates put the potential earnings impact at up to $30 million.

A company can have a fully compliant-looking Tier 1 relationship, while the actual forced-labor exposure sits two or three tiers upstream. Under UFLPA’s rebuttable presumption, the burden of proof sits with the importer, not the government, and CBP has been explicit that supplier self-declarations alone are increasingly insufficient.

$30M

analysts’ estimated earnings impact of the VSUN detentions

1,580%

increase in automotive/aerospace UFLPA detentions, 2023–2024

47%

of all UFLPA-detained shipments (Jun ’22–Dec ’24) ultimately denied entry

04 Organizational Readiness Check

Before committing further budget to visibility tools, it’s worth assessing where the organization actually sits across four dimensions, not just how much has already been spent.

DimensionEarly StageDevelopingAdvanced
Contractual Reach Beyond Tier 1Contracts and audit rights exist only with Tier 1 suppliers; sub-tier suppliers are unknown or informally identified at bestFlow-down disclosure clauses exist for a subset of critical categories; Tier 2 identified for high-risk commodities onlyStandard contracts include sub-tier disclosure and audit-cooperation clauses across all sourcing categories, not just flagged ones
Data StandardizationSupplier data collected via spreadsheets and email; no shared format across partnersTier 1 data integrated via EDI or supplier portals; sub-tier data, where it exists, arrives in inconsistent formatsShared data standards (Digital Product Passport schema, industry consortium formats) move data between buyer, supplier, and verification providers without manual translation
Verification MethodVisibility relies entirely on supplier self-attestation and periodic paper auditsTier 1 audited directly; sub-tier claims spot-checked occasionally, usually reactive to a specific regulatory requestIndependent verification, forensic testing, blockchain-recorded provenance, trade-data cross-checks, runs continuously as part of ongoing monitoring, not only after a shipment is detained
Regulatory IntegrationCompliance handled reactively, one regulation at a time, usually after a detention, audit finding, or customer requestA dedicated function tracks one or two major regulations (commonly UFLPA alone); data isn't shared across other requirementsA single due diligence data model feeds CSDDD, UFLPA, Scope 3 disclosure, and Digital Product Passport requirements at once, avoiding duplicated collection for each one

05 Key Implementation Steps: Choose Your Perspective

Click on the perspective you want to analyze – executives or analysts.

Executive View

Decide which categories actually need Tier 2+ visibility, and which don't.

Rank sourcing categories by regulatory exposure (CSDDD, UFLPA, EU Battery Regulation, Scope 3), single-source concentration, and reputational risk. Not every commodity needs isotopic testing or a blockchain passport; reserve the highest-cost verification methods for the categories where a stockout, detention, or disclosure failure would actually be damaging.

Put the contractual mechanism in place before the technology.

Amend Tier 1 contracts to require sub-tier disclosure and audit cooperation as a condition of doing business, not a voluntary request. Without that contractual leverage, a visibility platform has nothing to connect to below the purchase-order boundary, regardless of how capable the software is.

Fund independent verification alongside self-reported data, not instead of it.

Self-attestation and paper audits remain necessary, but Oritain’s 2026 research shows a widening gap between what brands believe about their sourcing and what independent testing confirms. Build verification cost into the sourcing budget for high-risk commodities from the outset.

Sequence the roadmap to regulatory deadlines, not a generic visibility ambition.

CSDDD, UFLPA, the EU Battery Regulation’s due diligence obligations (August 2027) and Digital Battery Passport requirement (February 2027), and Scope 3 disclosure rules each carry concrete dates. A roadmap built around named deadlines produces compliance evidence on the schedule regulators actually enforce.

Pilot in the category with the clearest existing exposure.

Choose one commodity or supplier tier where regulatory or reputational risk is already visible, and prove the model there first. Volvo and Circulor took six years to move from pilot to a commercially available battery passport; set board expectations for sub-tier visibility programs in years, not quarters.

Analyst View

Treat trade-data inference as a way to fill gaps, not replace supplier disclosure.

Bill-of-lading and customs data can reconstruct a supplier network even when a Tier 1 supplier declines to disclose its own upstream relationships. Cross-reference inferred networks against supplier-declared data to flag discrepancies; a mismatch is itself a risk signal worth investigating.

Build a tiered verification hierarchy instead of a single audit standard.

Reserve forensic and isotopic testing for the highest-risk raw materials (cotton, critical minerals, timber), documentation review for moderate-risk categories, and standard audits for the rest. Applying the most expensive verification method uniformly isn’t affordable; applying the cheapest method uniformly is how a verification gap opens.

Track the age of every sub-tier data point, not just whether it exists.

Sub-tier intelligence gathered at onboarding tends to go stale quickly, and industry research consistently points to onboarding data running well over a year old by the time it’s used in a live decision. Set a re-verification threshold by data type and risk category.

Score suppliers on disclosure willingness as its own risk category.

A Tier 1 supplier that declines to share upstream relationship data is not a neutral data gap — it should carry its own risk weighting, separate from whatever compliance score the supplier otherwise holds. This reframes a “no data available” result into an actionable signal.

Design any traceability platform choice for interoperability, not lock-in.

Battery passports, forensic testing providers, and trade-data platforms increasingly need to exchange data with each other, with customs authorities, and with the buyer’s own ERP. A single-vendor platform that can’t export to a common standard will need replacing the moment the next regulation lands.

06 Conclusion

The visibility gap below Tier 1 has stopped being a technology-availability problem, if it ever really was one. Every method described in this edition — trade-data inference, forensic verification, blockchain material passports — already exists and is already running in production at real companies today. What’s different about the organizations actually closing the gap is that they paired the technology with a contractual mechanism to reach past Tier 1, a verification method that doesn’t depend on a supplier’s paperwork being honest, and a roadmap sequenced to the regulatory dates that are now forcing the issue whether a company is ready or not.

The organizations that move first on sub-tier visibility now, ahead of the 2027 EU deadlines and the next round of UFLPA enforcement, will be making a deliberate choice. The ones that wait will likely be making the same choice for them.

In case you missed it – Previous Pulse Editions

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