Embedded Files
Title
Description and Timeline
Rationale and scope
Signatories
Challenges
Compliance Mechanisms
EU: Green Claims Directive (GCD)
The Green Claims Directive requires companies to use scientific and verifiable methods to support their environmental claims. It aims to standardize how environmental performance is presented and checked, mandating independent external verification and banning ambiguous terms such as "eco-friendly" or "climate neutral" unless fully explained.: March 2023: The European Commission formally adopted the proposal. Expected Transposition/Enforcement: Following its final adoption and publication, EU Member States are expected to have 18-24 months to transpose the directive into national law. Full compliance and enforcement are anticipated by late 2026 to 2027.
Combat greenwashing, ensure claims are substantiated and trustworthy. Voluntary environmental claims in B2C context across all sectors.
EU Member States. Businesses, verifiers, consumers, national authorities.
Scientific substantiation, verification capacity, fragmentation risk, overlap with other regulations.
Ex-ante verification, certificate of conformity, regular reporting. Financial sanctions, public statements, conduct orders (by Member State).
EU: Strategy for Sustainable and Circular Textiles
EU roadmap to make textiles durable, repairable, recyclable, and ethical by 2030. 30 March 2022: Strategy adopted by the European Commission. 2023–2024: Legislative development and adoption of supporting regulations: Ecodesign for Sustainable Products Regulation (ESPR). Digital Product Passport (DPP). Extended Producer Responsibility (EPR). Revised Waste Framework Directive (WFD). Green Claims Directive. By 1 January 2025: EU Member States must implement separate collection of textile waste.. By 2030: Full implementation goals to be met, including: All textile products meeting durability, repairability, and recyclability standards.. Significant reduction in environmental and social impacts of textiles.. Market-wide uptake of circular business models and supply chain transparency.
Reduce impact of textiles, promote circularity and sustainability. Textile and footwear lifecycle in the EU market.
EU Member States. Brands, producers, recyclers, consumers, public bodies.
Recycling infrastructure, tech advancement, transparency, behavior change.
Ecodesign, digital passport, EPR, destruction ban, surveillance. Fines, market restrictions (national laws).
EU Proposed regulation: Ecodesign for Sustainable Products Regulation (ESPR)
Proposed EU regulation to set minimum sustainability requirements for products, including textiles, making them more durable, reusable, and recyclable. Proposed March 2022.
Improve product sustainability and circularity across EU. Nearly all physical goods (excludes food, feed, medicine).
EU Institutions and Member States. Manufacturers, importers, retailers, recyclers.
Product-specific criteria, tech readiness, global impact, data needs.
Ecodesign, digital passport, destruction ban, surveillance. Fines, market withdrawal (national enforcement).
EU: Digital Product Passport (DPP)
Digital record under ESPR containing product lifecycle, traceability, and sustainability data. Part of ESPR (proposed March 2022); detailed requirements expected end 2025. Part of the EU Green Deal and Circular Economy Action Plan 2.0.
Increase transparency, traceability, circularity via product data. Product categories under ESPR including textiles, electronics, furniture.
EU Institutions and Member States. Manufacturers, retailers, recyclers, consumers.
Data standardization, infrastructure, governance, cost, global harmonization.
Unique ID, info requirements, accessibility, registration. Same as ESPR – fines, restrictions.
EU: Extended Producer Responsibility (EPR) for Textiles
EU framework making producers responsible for textile product collection, sorting, and recycling at end-of-life. Agreement reached late 2023; implementation expected by January 2025.
Make producers responsible for end-of-life textile management. Textile products, footwear, household linen in EU.
EU Member States. Producers, PROs, recyclers, consumers.
Scheme variation, costs, infrastructure, market demand, reporting.
Financial fees, PRO membership, eco-modulated fees. Fines, restrictions (national authority).
France: AGEC Law
Comprehensive circular economy law including mandatory sorting information and producer responsibility for textiles. Enacted February 2020
Accelerate circular economy transition and reduce waste. Multiple product categories including textiles, packaging, electronics.
French Government and Parliament. Businesses, PROs, waste operators, consumers.
Business adaptation, data collection, enforcement, reuse market.
EPR, eco-modulation, repairability index, destruction ban. Fines (up to €15,000), reputational damage.
Germany: Supply Chain Due Diligence Act (LkSG)
Requires companies to conduct human rights and environmental due diligence in their supply chains.: Came into force January 2023. (Note: While initially robust, there have been discussions in Germany about replacing it with a "low-bureaucracy" CSDDD transposition, potentially reducing its ambition).
Protect human rights and environment in supply chains. German companies with >1000 employees from 2024
German Government and Parliament. Companies, suppliers, NGOs, BAFA.
Complex supply chains, risk assessment, legal ambiguity.
Risk management, grievance procedures, annual reporting. Fines (up to 2% turnover), contract bans, lawsuits.
UK: Modern Slavery Act 2015
Requires businesses to publish annual statements on efforts to combat modern slavery in supply chains. Enacted 2015
Combat modern slavery in UK and supply chains. Businesses operating in UK with turnover >£36m
UK Parliament. Businesses, law enforcement, NGOs, victims.
Weak enforcement, minimal disclosures, complex supply chains.
Transparency statement, director sign-off, prosecution. Life imprisonment for offences, court orders, reputational risk.
EU Legislation: Corporate Sustainability Reporting Directive (CSRD)
A directive requiring companies to report detailed environmental, social, and governance (ESG) data, including sustainable fashion impacts. Came into force in January 2023. Replaces the Non-Financial Reporting Directive (NFRD).
Standardize sustainability reporting across EU economy. Large companies, SMEs, and non-EU firms by phase
EU Institutions and Member States. Companies, investors, NGOs, auditors, EFRAG.
Double materiality, assurance, data systems, talent gap.
Mandatory reporting, ESRS, digital tagging, assurance. Public disclosure, conduct orders, financial penalties.
USA: FABRIC Act
Federal legislation promoting ethical garment manufacturing and fair labor standards. Introduced May 2022; under review.
Combat labor abuses and support domestic garment industry. Garment manufacturers and brands in the U.S.
Senator Kirsten Gillibrand. U.S. Department of Labor, manufacturers.
Enforcement, industry compliance, bipartisan support.
Industry registry, wage standards. Penalties for wage violations.
USA: Uyghur Forced Labor Prevention Act (UFLPA)
Bans imports from Xinjiang unless proven not made with forced labor. Effective June 2022
Prevent human rights abuses in global supply chains. All imported goods, especially textiles.
President Joe Biden. CBP, importers.
Supply chain verification, trade tensions.
Clear evidence of clean supply chains. Detention or seizure of goods.
USA: California SB 707 – Responsible Textile Recovery Act
Creates EPR scheme for textile recycling. Signed Sep 2024; implemented by 2028
Reduce textile waste and improve recycling. Apparel producers and retailers in CA
Governor Gavin Newsom. CalRecycle, producers.
Recycling infrastructure, brand participation.
Producer-funded recycling programs. Fines, sales restrictions.
USA: California AB 405 – Fashion Environmental Accountability Act
Requires environmental due diligence and sustainability reporting. Introduced Feb 2025.
Increase transparency and reduce environmental impact. Fashion brands in California
Assemblymember Dawn Addis. DTSC, fashion companies.
Standardization, enforcement.
Annual sustainability reports. Penalties for non-compliance.
USA: New York Fashion Act
Mandates supply chain mapping and ESG disclosures. Introduced 2023; under review (May 2025)
Promote accountability in fashion supply chains. Fashion brands with >$100M global revenue in NY.
NY State Legislators. DEC, fashion brands.
Monitoring large corporations.
Mandatory disclosures. Fines, public naming.
USA: California SB 253 – Climate Corporate Data Accountability Act
Requires Scope 1–3 emissions disclosures. Effective 2026; first reports due 2027.
Drive corporate carbon transparency. Companies with >$1B revenue operating in CA
California State Legislature. CARB, large corporations.
Complex data collection, third-party assurance.
Annual reports, verification. Fines for non-disclosure.
USA: Voluntary Sustainable Apparel Labeling Act
Creates a voluntary eco-labeling program for apparel. Reintroduced Feb 2025.
Inform consumers on apparel sustainability. Voluntary for apparel companies
Reps. Casten and Salazar. EPA, FTC, fashion brands.
Standard development, industry uptake.
EPA guidelines. None (voluntary program).
USA: De Minimis Reform Legislation
Seeks to reform import threshold for duty-free goods. Introduced 2024.
Address trade imbalances and fair competition. Low-value imports, fashion goods from China
U.S. Congress. CBP, retailers.
Balancing policy with prices.
Adjust import limits, impose duties. Tariffs, import restrictions.
South Africa: Value-Added Tax (VAT) on Low-Value Imports
Removal of VAT Exemption (Effective September 1, 2024): The most significant change was the removal of the 15% import VAT exemption on consignments valued below ZAR 500. As an interim measure from September 1, 2024, all imported consignments for Business-to-Consumer (B2C) sales, regardless of value, became subject to the standard 15% VAT in addition to the existing 20% flat rate customs duty for low-value parcels. In addition, reconfiguration of Flat Rate Customs Duty (Effective November 1, 2024). From November 1, 2024, the South African Revenue Service (SARS) began reconfiguring the 20% flat rate into a new system aligned with the World Customs Organization (WCO) Guidelines on Immediate Release. This involves categorizing goods into four distinct categories, which will guide the tax treatment and applicable customs procedures. The aim is to introduce "appropriate duty rates" that are better catered to consignments' taxable value.
Leveling the Playing Field: The primary goal is to create a more equitable trading environment for local businesses and manufacturers. By making imports from international online retailers more costly, SARS aims to encourage consumers to shop from South African retailers. Also to protect local industry.
These were amendments to laws and therefore no new legislation needed to be voted on.
Complexity of Global E-commerce Supply Chains as it's difficult for SARS to gain full visibility into the entire e-commerce supply chain, from foreign seller to South African consumer. There are technological challenges eg Getting international e-commerce platforms (like Shein and Temu) to effectively integrate their systems with SARS's requirements for upfront VAT collection and accurate declarations at the point of sale is crucial but complex. Consumer Confusion and Frustration due to unexpected, estimated or misunderstood price changes.
Fines and Penalties usually a percentage of the undeclared value or even a fixed amount; Seizure and Forfeiture of Goods; and in cases of deliberate evasion, fraud, or repeated offenses, individuals or businesses involved can face criminal prosecution, potentially leading to imprisonment or severe criminal fines..
Nigeria: National Environmental (Textile, Wearing Apparel, Leather and Footwear Industry) Regulations
These regulations establish environmental standards for Nigeria's textile, apparel, leather, and footwear industries, aiming to minimize pollution and promote sustainable practices. 2009
To prevent and control pollution from industry operations, ensuring environmental protection and public health. Anecdotally up to 2025, success since 2009 has been limited. Applies to all facilities involved in textile, apparel, leather, and footwear production within Nigeria.
Issued by the Federal Ministry of Environment under the authority of the National Environmental Standards and Regulations Enforcement Agency (NESREA).
Monitoring and enforcement, and balancing economic growth with environmental protection.
Fines up to ₦1,000,000, with additional daily penalties for ongoing violations.
USA: California SB 62 - Garment Worker Protection Act
Mandates that garment workers be paid an hourly wage rather than per piece produced. Brands and retailers are held jointly liable for wage violations, even if the work is subcontracted. Importantly is also covers garment manufacturing operations including sewing, cutting, making, processing, repairing, finishing, assembling, dyeing, altering a garment's design (or causing another person to alter it), affixing a label to a garment, and otherwise preparing any garment or any article of wearing apparel or accessories designed or intended to be worn by any individual. This aims to minimise loopholes that might enable manaufacturers to claim that they did not manufacture the garment eg labelling. 2022.
This legislation aims to ensure fair compensation and improve labor conditions in the fashion industry.
While SB 62 represents a significant step toward improving labor conditions in California's garment industry, addressing enforcement challenges, industry concerns, and the complexities of supply chains is crucial to realizing its intended benefits. Industry groups, including the California Chamber of Commerce, have criticized SB 62, labeling it a "job killer." They argue that the law's joint liability provisions could deter brands from manufacturing in California, potentially leading to job losses and a shift of production to other regions or countries with less stringent regulations.
Bangladesh: Accord on Fire and Building Safety in Bangladesh
Legally binding agreement to improve factory safety in Bangladesh after the Rana Plaza collapse. 2013–2021
Address unsafe working conditions and prevent disasters in garment factories. Garment factories in Bangladesh
Global brands and retailers, international and local trade unions. Bangladeshi factory owners, inspection agencies, workers.
Ensuring full remediation, participation of all brands, maintaining transparency.
Independent inspections, public reports, brand funding of repairs. Legal enforcement of brand commitments, public disclosure of non-compliance.
Bangladesh,Pakistan and others: International Accord
Extended version of Bangladesh Accord and is exploring the feasibility (2025) of extending its programs to other major garment-producing countries, including India, Sri Lanka, and Morocco. 2021–present
Continue factory safety improvements and broaden geographic scope. Primarily Bangladesh, expanding to countries like Pakistan
Global brands, IndustriALL Global Union, UNI Global Union. Factories, local trade unions.
Expanding reach and ensuring continuity across jurisdictions.
Similar to original Accord: inspections, funding, public accountability. Termination of contracts, legal pressure from unions.
India: Dindigul Agreement
Legally binding agreement to end gender-based violence in Indian garment factories. 2022–present
Prevent workplace violence and abuse, improve worker wellbeing. Garment factories in Tamil Nadu, India
H&M, Gap, Eastman Exports, AFWA. Worker unions, Tamil Nadu government.
Cultural resistance, underreporting of abuse.
Worker committees, third-party monitoring, grievance redressal. Brand disengagement, reputational damage.
Pakistan Accord
Extension of the Bangladesh Accord focused on factory safety in Pakistan. 2023–present
Replicate Bangladesh's safety success in Pakistan. Garment factories in Pakistan
Brands, international unions. Pakistani manufacturers, local authorities.
Infrastructure differences, legal enforcement.
Inspections, transparency, remediation funding. Exclusion from supplier lists, disclosure.
China's IPR Laws in Fashion
Legal framework protecting fashion intellectual property in China. Ongoing, with updates since 2001 WTO accession
Combat counterfeiting, protect designer rights. Domestic and international fashion markets in China
Chinese government. Designers, brands, enforcement agencies.
Enforcement inconsistencies, judicial capacity.
Raids, administrative fines, lawsuits. Fines, imprisonment, brand de-listing.
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