Regulatory tracker: Fashion and textiles rules by jurisdiction — what's live, pending, and proposed

More than 35 new or updated textile regulations have entered enforcement, pending, or proposal stages across the EU, United States, United Kingdom, and Asia-Pacific since 2023. For fashion brands, retailers, and manufacturers, tracking which rules apply in which markets has become a compliance function in itself.

Why It Matters

The regulatory landscape for fashion and textiles is evolving faster than most compliance teams can track. Between the EU's Ecodesign for Sustainable Products Regulation, France's pioneering anti-waste laws, New York's proposed Fashion Act, and emerging extended producer responsibility (EPR) schemes across Asia, companies operating across borders face overlapping and sometimes contradictory requirements.

Non-compliance carries real consequences. France fined fashion brands over EUR 15 million in 2024 for misleading environmental claims under its AGEC law. The EU's Green Claims Directive, once enforced, will extend similar penalties across all 27 member states. Companies without jurisdiction-level visibility into upcoming rules risk product recalls, market access restrictions, and reputational damage that erodes brand equity built over decades.

The shift is structural: fashion regulation is moving from voluntary codes to mandatory law, from disclosure-only to product-level requirements, and from single-market rules to coordinated cross-border frameworks.

Key Concepts

Ecodesign for Sustainable Products Regulation (ESPR): The EU framework requiring textiles to meet minimum durability, repairability, and recyclability standards. Delegated acts for textiles are expected by 2027, with Digital Product Passports (DPPs) required for apparel products.

Extended Producer Responsibility (EPR): Regulations making brands financially responsible for the end-of-life management of textile products they place on a market. France pioneered textile EPR through Re_fashion (formerly Eco-TLC) in 2007, and the EU is mandating member-state EPR schemes by 2025.

Digital Product Passport (DPP): A digital record attached to each product containing information about materials, origin, environmental footprint, and recyclability. The EU requires DPPs for textiles under ESPR, with phased implementation beginning in 2027.

Green Claims Directive: EU legislation requiring companies to substantiate environmental marketing claims with verified data and standardized methodologies. Bans generic claims such as "eco-friendly" or "sustainable" without supporting evidence.

Due Diligence Legislation: Laws requiring companies to identify, prevent, and mitigate adverse human rights and environmental impacts throughout their supply chains, including the EU Corporate Sustainability Due Diligence Directive (CSDDD) and Germany's Supply Chain Due Diligence Act (LkSG).

Jurisdiction Tracker

European Union: Live and Pending

Live regulations:

• EU Waste Framework Directive (Textile EPR mandate): Requires all member states to establish separate textile collection by January 2025. Member states must implement EPR schemes for textiles, with producers bearing costs for collection, sorting, reuse, and recycling.
• CSRD (Corporate Sustainability Reporting Directive): Large fashion companies meeting thresholds must report sustainability metrics including textile-specific environmental impacts. First reports due in 2025 for FY2024 data.
• EU Strategy for Sustainable and Circular Textiles: Adopted March 2022, sets the framework for binding measures on durability, recyclability, fiber content transparency, and microplastic shedding.

Pending regulations:

• ESPR Delegated Acts for Textiles: Expected 2027. Will set mandatory minimum requirements for durability, repairability, recyclability, recycled content, and microfiber release. Will also require DPPs for textile products.
• Green Claims Directive: Proposed March 2023, expected enforcement by 2026-2027. Requires pre-approval of environmental claims and bans generic sustainability labels without third-party certification.
• CSDDD: Adopted 2024, phased implementation through 2029. Requires large companies to conduct human rights and environmental due diligence across supply chains, directly affecting sourcing in garment-producing countries.

France: The Leading Jurisdiction

Live regulations:

• AGEC Law (Anti-Waste for a Circular Economy): Effective since 2020, with progressive enforcement. Bans destruction of unsold non-food goods including textiles (effective 2022). Requires environmental labeling for clothing and footwear. Mandates repairability information where applicable.
• Climate and Resilience Law (Article 13): Requires environmental display scores for textiles and footwear. France's Affichage environnemental program assigns scores based on lifecycle analysis, covering carbon, water, biodiversity, and resource use.
• Re_fashion EPR Scheme: Operating since 2007, requires fashion brands selling in France to register, pay eco-contributions, and meet collection and recycling targets. In 2024, eco-modulation fees penalize products with low durability or recyclability.

Pending regulations:

• Proposed fast-fashion penalty: Legislation under consideration to impose surcharges on ultra-low-cost garments, targeting platforms selling items priced under EUR 10 with environmental penalty fees. Passed initial reading in the French National Assembly in March 2024.

United Kingdom: Post-Brexit Framework

Live regulations:

• UK Environment Act 2021: Grants powers to introduce EPR for textiles, though textile-specific regulations have not yet been enacted. Packaging EPR (live from 2024) provides a template.
• Competition and Markets Authority (CMA) Green Claims Code: Guidance (not legislation) on environmental claims. The CMA has investigated and taken action against fashion brands for misleading sustainability marketing, including investigations into ASOS and Boohoo in 2023.

Pending regulations:

• Textile EPR consultation: DEFRA launched a call for evidence on textile EPR in 2023. A formal consultation is expected by late 2026, with implementation unlikely before 2028.
• UK Green Taxonomy: Under development, will classify sustainable economic activities including textile manufacturing and recycling.

United States: State-Level Action

Live regulations:

• California SB 707 (Textile Recovery Act): Signed 2024, establishes a producer responsibility framework for textiles in California. Producers must register and fund collection and recycling infrastructure by 2026.
• New York City Local Law 144: While focused on AI in hiring, sets a precedent for supply chain transparency laws that intersect with fashion labor practices.
• FTC Green Guides: Federal guidance on environmental marketing claims. Updated guides expected by 2025-2026, with tighter requirements on recyclability claims and "sustainable" labeling.

Pending and proposed regulations:

• New York Fashion Act (S4746): Proposed legislation requiring fashion companies with revenues above $100 million to map at least 50% of their supply chains, disclose environmental and social impacts, and set binding reduction targets. Reintroduced in 2025 after failing to pass in previous sessions.
• California SB 253/SB 261 (Climate Disclosure): While not textile-specific, mandates emissions disclosure for companies with California revenues above $1 billion, capturing most major fashion brands.
• FABRIC Act (federal): Proposed legislation to hold fashion brands jointly liable for labor violations at contracted garment factories in the United States.

Asia-Pacific: Emerging Frameworks

Live regulations:

• Bangladesh Accord (International Accord for Health and Safety): Binding agreement covering 2 million+ garment workers. Renewed in 2023, now expanded beyond fire and building safety to include wages and environmental standards.
• India's EPR for Packaging: Mandates plastic packaging producers (including fashion brands using polybags) to meet recycling targets. Textile-specific EPR under discussion.
• China's Dual Carbon Policy: National carbon targets indirectly affect textile manufacturing through energy consumption limits and emissions caps on industrial facilities. Zhejiang and Guangdong provinces have implemented textile-specific efficiency standards.

Pending and proposed regulations:

• Australia's proposed Fashion Transparency legislation: Follows from the Modern Slavery Act (2018). Consultations in 2024 on mandatory environmental and labor supply chain disclosure for fashion brands.
• Japan's Green Transformation (GX) strategy: Includes textile circularity targets and potential mandatory recycled content requirements for clothing sold in Japan.

What's Working

France's integrated approach demonstrates that combining EPR, environmental labeling, and destruction bans creates measurable outcomes. Re_fashion collected 248,000 tonnes of used textiles in 2023, a 15% increase from 2022, with reuse and recycling rates reaching 59%. The eco-modulation mechanism is pushing brands to improve product durability: early data shows a 12% increase in average garment weight (a proxy for durability) in categories subject to eco-modulated fees.

California's textile EPR leadership in the United States proves that state-level action can drive national change. SB 707's passage prompted Oregon and Washington to introduce similar bills in their 2025 legislative sessions, creating momentum toward a patchwork that may eventually push federal harmonization.

The International Accord in Bangladesh shows that binding agreements with enforcement teeth outperform voluntary commitments. Workplace fatalities in covered factories dropped 82% since the original Accord began in 2013, and the expanded scope now addresses environmental discharge standards at dyeing and finishing facilities.

What's Not Working

Regulatory fragmentation across EU member states undermines the single market. Despite the EU-level textile strategy, member states are implementing EPR schemes with different fee structures, collection targets, and definitions of recyclability. A brand selling in France, Germany, and the Netherlands faces three distinct compliance regimes, with no harmonized reporting format or mutual recognition of eco-contributions.

Voluntary industry initiatives have failed to deliver scale. The Fashion Pact, signed by 60+ companies representing a third of the industry, set ambitious targets in 2019 but lacks binding enforcement. A 2024 review found that aggregate member emissions rose 2.4% despite individual company pledges. Without regulatory backstops, voluntary commitments function as communications exercises rather than transition mechanisms.

Supply chain visibility remains shallow. Most fashion brands can trace Tier 1 suppliers (cut-and-sew factories) but fewer than 25% have visibility beyond Tier 2 (fabric mills). Forthcoming due diligence requirements under the CSDDD and proposed New York Fashion Act demand deeper mapping, but the infrastructure for multi-tier traceability across fragmented garment supply chains does not yet exist at scale.

Key Players

Established Leaders

• Kering: Luxury conglomerate operating an Environmental P&L since 2012. First fashion group to achieve third-party verified Scope 3 accounting across all brands including Gucci and Balenciaga.
• H&M Group: Largest collector of used garments globally through in-store take-back programs. Processes 30,000+ tonnes annually through its Looper subsidiary.
• Inditex: Zara parent implementing circular design standards across 12 brands. Committed to 100% sustainably sourced cotton, linen, and polyester by 2025.

Emerging Startups

• Reverse Resources: Platform connecting textile manufacturers with recyclers, tracking waste streams from 400+ factories across 15 countries.
• TextileGenesis: Blockchain-based fiber traceability platform used by Lenzing, H&M, and Target for chain-of-custody verification from fiber to retail.
• Resortecs: Develops thermally disassemblable stitching threads that enable automated garment disassembly for recycling at end of life.

Key Investors and Funders

• Fashion for Good: Amsterdam-based innovation platform backed by Adidas, Kering, and Target, funding 200+ circular textile startups.
• Closed Loop Partners: Investment firm deploying capital into textile recycling infrastructure across North America.
• European Investment Bank: Provided EUR 200 million in financing for textile circularity projects under the EU's Circular Economy Action Plan.

Action Checklist

1. Map every jurisdiction where your products are sold and identify which textile regulations are live, pending, or proposed in each market.
2. Register with EPR schemes in France (Re_fashion) and California (SB 707) if you meet thresholds, and monitor pending EPR consultations in the UK and additional US states.
3. Audit all environmental marketing claims against the EU Green Claims Directive requirements and the CMA Green Claims Code, removing any unsubstantiated language before enforcement begins.
4. Begin Digital Product Passport readiness by digitizing material composition, supplier origin, and care instruction data for your top-selling product lines.
5. Invest in supply chain mapping beyond Tier 1 to prepare for CSDDD and proposed due diligence requirements, prioritizing high-risk sourcing countries.
6. Establish relationships with textile recycling and take-back partners in markets with collection mandates, ensuring your products can enter circular end-of-life pathways.
7. Build internal tracking dashboards that monitor regulatory timelines across jurisdictions and assign compliance ownership for each rule.

FAQ

Which jurisdiction has the strictest fashion regulations right now? France leads globally with the most comprehensive set of live textile regulations, including EPR (since 2007), mandatory environmental labeling, bans on destroying unsold goods, and proposed fast-fashion surcharges. The EU-wide framework will eventually harmonize many of these rules, but France remains 3-5 years ahead of most member states.

When will Digital Product Passports be required for textiles? The EU's ESPR framework requires DPPs for textiles, with delegated acts expected by 2027 and phased enforcement likely beginning in 2028-2029. Companies should begin digitizing product data now, as the technical infrastructure requires 18-24 months to implement across product lines.

How does the New York Fashion Act compare to EU regulations? The proposed Fashion Act focuses on supply chain mapping and impact disclosure for companies above $100 million in revenue. It is narrower than the EU's combined framework (which includes product design, EPR, labeling, and due diligence) but would be the first US legislation specifically targeting fashion sustainability at scale. As of early 2026, it has not yet passed into law.

What penalties exist for non-compliance? Penalties vary by jurisdiction. France has issued fines exceeding EUR 15 million for misleading environmental claims. The EU Green Claims Directive proposes penalties of at least 4% of annual turnover. California's SB 707 includes administrative penalties for non-registration. In most jurisdictions, penalties escalate for repeat violations and can include market access restrictions.

Should brands prepare for regulations that haven't passed yet? Yes, for two reasons. First, implementation timelines for complex requirements (supply chain mapping, DPPs, EPR registration) typically require 12-24 months, meaning brands that wait for final legislation will face compliance gaps. Second, early adopters gain competitive advantages in operational efficiency and brand credibility that justify the investment regardless of regulatory timing.

Sources

1. European Commission. "EU Strategy for Sustainable and Circular Textiles." EC, 2022.
2. Re_fashion. "2023 Annual Report: Textile Collection and Recycling in France." Re_fashion, 2024.
3. California Legislature. "SB 707: Responsible Textile Recovery Act." State of California, 2024.
4. European Commission. "Proposal for Ecodesign for Sustainable Products Regulation." EC, 2022.
5. International Accord for Health and Safety in the Textile and Garment Industry. "2023 Annual Report." International Accord Foundation, 2024.
6. New York State Senate. "S4746: Fashion Sustainability and Social Accountability Act." NY Senate, 2025.
7. European Commission. "Proposal for a Directive on Green Claims." EC, 2023.
8. McKinsey & Company. "The State of Fashion 2025." McKinsey, 2024.