UPDATED: Mar. 3, 2026
Retail has long operated in an environment characterized by fragmented and relatively limited sustainability oversight. While certain sectors – such as food and pharmaceuticals – have faced comprehensive regulation for decades, most retail companies have historically navigated a landscape in which environmental and social governance standards largely fall under voluntary commitments, industry-developed frameworks, and marketing-driven sustainability claims. This reality has persisted even as supply chains have grown more expansive and opaque, consumer demand for transparency has intensified, and sustainability performance has increasingly become tied to brand value and competitive positioning.
In this context, many retailers have leaned on an array of self-regulatory tools – from third-party certifications and lifecycle assessment methodologies to internally developed sustainability roadmaps and net-zero pledges. Yet, such efforts often lack enforceability. Without legal or financial consequences for failing to meet stated goals, these initiatives can result in uneven accountability and, in some cases, risk becoming vehicles for overstated or misleading environmental claims.
Meanwhile, the regulatory measures that do exist have proven incomplete or difficult to enforce. For example, product safety and consumer protection laws often place responsibility on the buyer to evaluate the quality and sustainability of goods, while labor protections may be undermined by multi-tier subcontracting structures that diffuse responsibility across a chain of suppliers and intermediaries.
This status quo is shifting. Governments across key markets are moving toward more prescriptive sustainability rules aimed at curbing waste, increasing supply chain transparency, and aligning corporate sustainability disclosures with standardized, verifiable metrics. Europe is at the forefront of this shift, advancing legislation to restrict the destruction of unsold products, require detailed environmental labeling, and impose mandatory human rights and environmental due diligence across supply chains. Similar proposals – ranging from climate disclosure mandates to textile waste management and extended producer responsibility programs – are gaining momentum at the federal and state levels in the United States.
Against this backdrop, retail companies face a quickly evolving legal environment. With that in mind, here is a running list of key domestic and international legislation that industry occupants should be aware of – and we will continue to track developments for each and update accordingly …
Introduced: Mar. 3, 2026
Snapshot: Proposed EU regulation aimed at expanding demand for low-carbon and European-manufactured industrial products through public procurement rules, foreign investment conditions, and streamlined permitting. While framed as an industrial decarbonization measure, the Industrial Accelerator Act (IAA) also carries implications for automotive and retail supply chains, particularly by encouraging local sourcing and expanding EU manufacturing capacity in strategic sectors such as electric vehicles, batteries, and clean technologies.
Key Provisions: The Act introduces “Made in EU” and low-carbon preferences in public procurement and funding across sectors including automotive, steel, aluminum, and clean technologies, potentially favoring EU-manufactured EVs and components in public fleet purchases and infrastructure programs. By prioritizing European-made inputs and lower-emissions materials, the measure may push automakers and consumer-goods companies to shift sourcing toward EU suppliers, particularly for metals, batteries, and clean-energy technologies. It also places conditions on foreign investments above €100 million in sectors such as EVs, batteries, and critical raw materials, including technology transfer obligations and a minimum 50% European workforce where global manufacturing capacity is concentrated in a single third country.
The proposal further seeks to accelerate clean manufacturing through Industrial Acceleration Areas and streamlined digital permitting for large industrial projects such as battery gigafactories and EV plants. Together, these measures could increase pressure on automakers, retailers, and brands operating in the EU to demonstrate greater local sourcing and supply-chain transparency, particularly where public procurement or government subsidies are involved.
Adopted: Feb. 9, 2026, by the European Commission under Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation).
Snapshot: The European Commission adopted a Delegated Act and an Implementing Act to operationalize rules under the ESPR prohibiting the destruction of unsold apparel, clothing accessories, and footwear. The measures are intended to reduce textile waste and associated emissions by restricting the disposal of excess inventory and reinforcing the EU’s circular economy framework.
Key Provisions: The Delegated Act confirms the ban on the destruction of unsold apparel, clothing accessories, and footwear listed in Annex VII of the ESPR. The ban applies to large companies beginning July 19, 2026, and to medium-sized companies starting in 2030; micro and small enterprises are exempt. The Delegated Act also clarifies limited derogations, including destruction for safety reasons or where products are damaged. National authorities are responsible for enforcement.
Separately, Article 24 of the ESPR requires companies to disclose information on unsold consumer products discarded as waste. That disclosure obligation has applied to large companies since July 19, 2025, and will extend to medium-sized companies in 2030. The Implementing Act adopted on Feb. 9, 2026 establishes a standardized format for such disclosures, applicable from February 2027.
Potential Implications: The measures transform the destruction of excess stock from a reputational and ESG issue into a formal compliance matter under EU product law. Fashion and footwear companies placing products on the EU market will need to reassess inventory planning, returns management, and resale, donation, or reuse strategies to mitigate regulatory and enforcement risk.
Introduced: Jan. 22, 2026, by Rep. Murphy (NC) with bipartisan co-sponsors
Snapshot: The Buying American Cotton Act of 2026 (H.R. 7230) proposes a new federal tax credit to incentivize the domestic consumption of U.S.-grown cotton. The bill aims to bolster the American cotton industry and enhance supply chain transparency through digital tracing and certification systems.
Key Provisions: The bill would establish a Domestic Cotton Consumption Credit based on the volume of U.S.-origin cotton in eligible consumer articles. It provides a higher credit for cotton yarn (1.6× multiplier) and cotton fabric (6.5× multiplier) made in the U.S. The credit applies only to goods sold to unrelated parties for U.S. consumption or income connected to U.S. trade or business. It also requires digital tracing of cotton through the supply chain and certification of U.S. origin. Credit values vary depending on whether processing occurred in countries with free trade agreements or covered by unilateral preference programs. To prevent abuse, the bill includes provisions ensuring that the same volume of cotton cannot receive credit more than once.
Potential Implications: Lawmakers see the bill as a strategic economic and trade tool. “This legislation rewards companies that choose American-grown cotton and invest in our domestic supply chain,” said Rep. Murphy. “It’s about strengthening rural economies, promoting transparency, and ensuring our cotton industry remains globally competitive.”
Introduced: July 2, 2025 by the European Commission
Snapshot: The Commission proposes to amend Regulation (EU) 2021/1119 (the European Climate Law) to establish a binding Union-wide 2040 climate target of a 90 percent net reduction in greenhouse gas emissions compared to 1990 levels. The amendment sets the overarching trajectory for EU climate policy beyond 2030, guiding future legislative revisions across energy, industrial, and environmental sectors. Although the proposal does not directly regulate retail or consumer products, it signals future tightening of sectoral climate rules that will eventually affect large retailers and consumer-goods companies through downstream legislation.
Key Provisions: The legislation requires that (1) the EU adopt a binding 2040 target of a 90 percent net reduction in greenhouse gas emissions compared to 1990 levels; (2) the Commission review and revise post-2030 climate and energy legislation to align with the 2040 target, including potential adjustments to the EU Emissions Trading System, Effort Sharing Regulation, and LULUCF framework; (3) future legislative proposals incorporate criteria such as cost-effectiveness, fairness, competitiveness, technological neutrality, and just-transition considerations; (4) the Commission assess the limited possible use of high-quality international carbon credits after 2036, subject to strict EU rules; and (5) domestic removals, including nature-based and technological solutions, be integrated into the pathway toward meeting the 2040 target and the 2050 climate-neutrality objective.
Potential Implications: The proposal does not impose direct obligations on retailers or consumer-goods companies. However, the 2040 target will drive future policy changes that indirectly affect retail supply chains, including stricter product-design rules, energy-efficiency standards, emissions-intensity requirements, and sustainability reporting obligations. Companies operating in the EU can expect additional climate-related regulatory updates across transport, packaging, manufacturing, and energy-intensive sectors as the Commission revises existing legislation to align with the new trajectory.
Status: pending consideration by the European Parliament and Council.
Introduced: February 2025 by the Environment Committee.
Snapshot: HB 6917 directs the Connecticut Department of Energy and Environmental Protection (DEEP) to study the feasibility of implementing a statewide EPR program for packaging waste.
Key Provisions: The legislation requires that (1) DEEP assess current packaging waste volumes, recycling rates, and infrastructure; (2) the agency evaluate cost-sharing models that shift recycling costs from municipalities to producers; (3) other states’ EPR frameworks, including those in Maine, Oregon, Colorado, and Maryland, be reviewed; and (4) the department recommend legislative pathways for implementing an EPR system in Connecticut.
Potential Implications: While the bill does not yet establish a full EPR system, it positions Connecticut as a likely adopter in the next legislative cycle, aligning the state with regional and national packaging reform efforts.
Status: In Committee (pending as of Nov. 2025)
Introduced: February 27, 2025 by Rep. Joshua Heintzeman (R) with Rep. Jeff Backer (R) as co-author.
Snapshot: HF1627 refines Minnesota’s existing PFAS Product Reporting and Prohibition framework by extending compliance deadlines, clarifying exemptions, and adjusting how PFAS use must be disclosed.
Key Provisions: The bill would (1) delay the deadline for PFAS product reporting from January 1, 2026 to January 1, 2028; (2) it would also exempt commercial and industrial-use products and internal electronic components from PFAS restrictions until 2032; (3) modify definitions and reporting categories to align with federal EPA guidance; (4) extend exemptions for firefighting foams used in airports and certain industrial facilities.
Potential Implications: HF1627 would provide manufacturers with additional time to reformulate and improve supply-chain transparency. It balances regulatory feasibility with Minnesota’s goal of phasing out intentionally added PFAS.
Status: Introduced and referred to committee; pending legislative action.
Introduced: Feb. 4, 2025 by New York Assemblymember Dr. Anna Kelles (D).
Snapshot: The Fashion Environmental Accountability Act (A4631-B) would require major fashion companies to conduct environmental due diligence across their supply chains and publicly report on their environmental impacts. The measure aims to hold brands accountable for pollution, emissions, and chemical use throughout textile production.
Key Provisions: The bill would require fashion sellers to (1) publish an annual Environmental Due Diligence Report verified by a third party; (2) map and disclose key parts of their global supply chain, including fabric mills and processing facilities (3) identify, assess, and mitigate environmental risks, including chemical discharges and greenhouse-gas emissions; (4) establish and report quantitative greenhouse-gas baselines and reduction targets consistent with science-based goals; and (5) contribute to a new Fashion Remediation Fund supporting pollution-reduction and sustainability projects.
Potential Implications: “This bill ensures transparency and accountability from the world’s largest fashion brands,” said Assemblymember Kelles. “By tracing products from fiber to finished garment, we can reduce waste, curb emissions, and protect the people and places impacted by production.”
Status: Referred to the Committee on Environmental Conservation.
Introduced: January 29, 2025 by Reps. Joanne Ferrary (D), Debra Sariñana (D), Dayan Hochman-Vigil (D), Kathleen Cates (D), and Sen. Jeff Steinborn (D).
Snapshot: A consumer safety bill designed to protect New Mexicans—especially children—from exposure to PFAS (“forever chemicals”) in common household and juvenile products. The law phases out and ultimately bans the sale of products with intentionally added PFAS, addressing health risks linked to developmental, immune, and reproductive harm.
Key Provisions: (1) From 2027, bans on PFAS-containing cookware, food packaging, juvenile products, dental floss, and firefighting foam, unless deemed essential; (2) From 2028, bans on PFAS-containing carpets, cleaning products, feminine hygiene products, and cosmetics; and (3) From 2032, bans on all other non-exempt consumer products containing intentionally added PFAS.
Implications: New Mexico joins at least eight other states, including Colorado, Minnesota, and California, in adopting PFAS restrictions. The Act aligns with nationwide efforts to curb PFAS exposure in consumer goods and prioritizes protection of children, who face heightened vulnerability through direct contact, household exposure, and maternal transfer.
Status: Enacted March 10, 2025.
Introduced: January 22, 2025, by Sen. Eliot Bostar (D).
Snapshot: Nebraska’s LB 607 establishes new producer obligations affecting retail and consumer brands, particularly those selling products with packaging, paper materials, or batteries in the state. The bill aims to increase recycling transparency and set recycled-content standards that directly influence how consumer goods are packaged and marketed.
Key Provisions: The legislation requires that (1) producers of packaging and paper products selling into Nebraska report annual material volumes and composition under a new data-collection program, creating future groundwork for packaging-reduction requirements; (2) battery producers or importers selling portable or medium-format batteries join a stewardship organization by 2027 to manage collection and recycling; and (3) manufacturers and consumer-goods companies meet a minimum 30 percent post-consumer recycled-content standard for plastic packaging beginning in 2028.
Potential Implications: Retailers and consumer-goods brands selling into Nebraska will face new reporting duties and supply-chain verification requirements for packaging materials. The law pressures companies to source packaging with verified recycled content and plan for compliance with potential future extended-producer-responsibility mandates. Battery-powered consumer products will also require alignment with stewardship and take-back programs.
Status: Referred to the Natural Resources Committee. As of November 2025, LB 607 remains in committee and will expire with the close of the 2025 legislative session if not advanced.
Introduced: January 16, 2025 by Sen. Sal N. DiDomenico (D).
Snapshot: Massachusetts’ S571, An Act to Reduce Waste and Recycling Costs in the Commonwealth, would create a statewide extended producer responsibility (EPR) framework for packaging and paper products. The proposal directly affects retail and consumer-goods brands selling packaged items in Massachusetts, shifting responsibility for recycling costs and waste management from municipalities to producers.
Key Provisions: The legislation requires that (1) producers of packaging and paper products—including brand owners, importers, and franchisors—join a Packaging Reduction Organization (PRO) to finance and manage recycling and packaging-reduction programs; (2) producers pay fees based on the weight, recyclability, and toxicity of materials placed on the market, with eco-modulated rates favoring recyclable and non-toxic packaging; (3) all producers report packaging volumes annually and meet phased minimum post-consumer recycled-content requirements beginning at 10% by 2035; (4) online retailers and franchisors selling or distributing products in Massachusetts be treated as producers, ensuring e-commerce and franchise brands comply equally; and (5) producers that fail to participate in the program be prohibited from selling or distributing covered products in the state, with potential fines up to $200,000 per violation.
Potential Implications: Retailers, consumer-goods companies, and e-commerce brands selling into Massachusetts would face significant packaging redesign and reporting obligations. The law would require sourcing recyclable and non-toxic packaging, implementing supply-chain data systems, and budgeting for producer fees tied to material weight and sustainability. Franchisors would be directly liable for compliance, not local franchisees, increasing oversight requirements for national chains.
Status: Referred to the Joint Committee on Environment and Natural Resources in February 2025. Pending as of November 2025.
Introduced: January 2025 by Sen. Pete Harckham (D).
Snapshot: New York’s S1464 replaces previous attempts at establishing a statewide Extended Producer Responsibility (EPR) framework. The measure requires packaging producers to fund, design, and manage the state’s recycling system, implement packaging-reduction targets, and phase out toxic materials. The bill positions New York among the most comprehensive state packaging laws in the U.S., following the models set by Maine, Oregon, and Colorado.
Key Provisions: The legislation requires that (1) producers join a not-for-profit Packaging Reduction and Recycling Organization (PRO) to design and operate a statewide program under oversight by the Department of Environmental Conservation; (2) producers meet escalating packaging-reduction targets of 10–30% and minimum post-consumer recycled content standards for glass, paper, and plastic; (3) toxic substances such as PFAS, bisphenols, and heavy metals be phased out from packaging within three to five years; (4) the PRO fund and reimburse local governments for collection, recycling, and infrastructure improvements; and (5) an Office of Recycling Inspector General be established to oversee compliance and enforcement.
Potential Implications: The law shifts recycling and waste-management costs from municipalities to packaging producers, requiring brands operating in New York to redesign products for circularity, invest in recyclable and refillable materials, and comply with strict reporting and toxic-substance restrictions. It is expected to reshape packaging design and material sourcing across consumer goods sectors.
Status: Passed Senate. In Committee (pending as of Nov. 2025).
Introduced: February 16, 2023 by Senators Josh Newman, Nancy Skinner and Scott Wiener
Snapshot: The bill (SB 707) would establish an Extended Producer Responsibility scheme for the collection and recycling of “covered products,” which include any apparel, textile, or textile article that is unsuitable for reuse by a consumer in its current state or condition.
Gov. Gavin Newsom signed SB 707 into law on September 28, 2024 and subsequently Chaptered by Secretary of State (Chapter 864, Statutes of 2024), thereby, establishing the first Extended Producer Responsibility (EPR) textile recycling program in the U.S. “SB 707 isn’t just about recycling; it’s about transforming the way we think about textile waste,” Senator Josh Newman (D-Fullerton), the bill’s author, said in a statement. “The framework created by SB 707 will create new opportunities for every Californian to participate in a more sustainable future.”
Status (Feb. 27, 2026): CalRecycle has selected Landbell USA to serve as the producer responsibility organization (PRO) responsible for implementing California’s textile extended producer responsibility law, the Responsible Textile Recovery Act of 2024 (S.B. 707). As the designated PRO, Landbell will develop and oversee a statewide system for collecting, transporting, repairing, reusing, and recycling apparel and textile products sold in California, with producers required to join the program by July 1, 2026.
Introduced: June 3, 2024 by Sen. Bob Smith (D) and Sen. Paul D. Moriarty (D).
Snapshot: New Jersey’s S3398, the Packaging Product Stewardship Act, would establish an extended producer responsibility (EPR) framework requiring packaging producers to finance and manage the collection, recycling, and reduction of packaging materials. The measure aims to modernize New Jersey’s recycling system, reduce single-use packaging, and shift recycling costs from municipalities to producers.
Key Provisions: The legislation requires that (1) producers join or form a Producer Responsibility Organization (PRO) or submit an individual stewardship plan within two years of enactment; (2) a statewide needs assessment identify infrastructure and investment requirements for meeting source-reduction and recycling goals; (3) producers achieve a 25 percent reduction in single-use packaging by 2032, ensure all packaging is recyclable or compostable by 2034, and reach a 65 percent recycling rate by 2036; (4) PROs impose eco-modulated fees based on recyclability, toxicity, and material composition to fund program costs; and (5) an Office of Plastics and Packaging Management within the Department of Environmental Protection oversee enforcement and administer the Packaging Reduction and Recycling Fund, financed by producer surcharges of up to $120 million annually.
Potential Implications: If enacted, the law would require packaging producers, consumer-goods companies, and retailers operating in New Jersey to redesign products for recyclability, increase use of recycled content, and fund statewide waste-management infrastructure. The law incentivizes lighter, non-toxic, and recyclable packaging designs, forcing many national brands to harmonize packaging specifications across states adopting similar EPR laws.
Status: In Committee (pending as of Nov. 2025).
Introduced: February 2024 by Sen. Malcolm Augustine.
Snapshot: Maryland’s SB 901 establishes an extended producer responsibility (EPR) program for packaging and paper products, requiring producers to fund and manage the collection, reuse, and recycling of covered materials. It is one of the most comprehensive EPR laws in the U.S., modeled on frameworks adopted in Oregon and Colorado.
Key Provisions: The legislation requires that (1) producers of packaging and paper products join a Producer Responsibility Organization (PRO) by 2027; (2) producers submit a producer responsibility plan to the Maryland Department of the Environment (MDE) for approval; (3) packaging reduction and recyclability performance targets be established and tracked; (4) eco-modulated fees incentivize recyclable, compostable, and non-toxic materials; and (5) an advisory council be created to oversee program implementation and stakeholder input.
Potential Implications: The law shifts recycling costs from local governments to producers, requiring packaging and retail brands operating in Maryland to redesign materials for circularity and supply-chain transparency.
Status: Enacted May 9, 2025. Signed by Governor Wes Moore.
Introduced: January 29, 2024 by Sen. Lisa Cutter (D) and Reps. Cathy Kipp (D) and Manny Rutinel (D).
Snapshot: House Bill 24-1148 expands Colorado’s restrictions on products containing intentionally added PFAS (“forever chemicals”) by adding new product categories and refining reporting and compliance timelines.
Key Provisions: The bill would (1) broaden the definition of consumer products covered under Colorado’s 2022 PFAS law; (2) add new restrictions on categories such as cosmetics, cookware, and apparel that contain intentionally added PFAS; (3) require manufacturers to disclose PFAS content and phase out restricted substances by set compliance dates; (4) empower the state to issue rules specifying future product bans and labeling standards.
Potential Implications: Colorado continues to lead on state-level PFAS regulation. The expanded list would require manufacturers, importers, and retailers to verify supply-chain compliance earlier and more comprehensively than under prior law.
Status: Original law enacted June 1st, 2022. Improvement act enacted May 1st, 2024.
Introduced: January 2024 by Sen. Christine Rolfes (D).
Snapshot: SB 5284 overhauls Washington’s recycling system and establishes a statewide EPR framework for packaging materials, making Washington one of the first states to adopt full producer responsibility for packaging waste.
Key Provisions: The legislation requires that (1) packaging producers join a Producer Responsibility Organization (PRO) and fund statewide recycling operations; (2) phased packaging-reduction targets and post-consumer recycled content requirements be implemented; (3) toxic additives and certain single-use materials be prohibited; (4) a uniform statewide list of accepted recyclables be created; and (5) the Department of Ecology establish performance standards for recycling facilities and curbside collection.
Potential Implications: The law reduces local government recycling costs, standardizes recycling rules statewide, and requires packaging and consumer goods companies to finance recycling infrastructure and report lifecycle data.
Status: Enacted May 2025. Implementation to begin in 2027.
Introduced: July 2023 by the European Commission
Snapshot: The proposal amends the EU Waste Framework Directive (2008/98/EC) to address two high-impact waste streams: textiles and food waste. It aims to reduce environmental harms linked to fast fashion and EU-wide food waste, strengthen circular-economy systems, and establish harmonized rules across Member States. The initiative builds on the European Green Deal and the EU Strategy for Sustainable and Circular Textiles.
Key Provisions: The legislation requires that (1) Member States implement extended producer responsibility (EPR) for textiles to finance collection, sorting, reuse, and recycling; (2) common definitions, reporting rules, and quality standards be established for textile waste and reuse/recycling processes; (3) Member States achieve binding food-waste reduction targets at processing, retail, services, and household levels by 2030; and (4) national food-waste prevention strategies include coordinated measures across the supply chain, supported by EU monitoring and harmonized measurement methodologies.
Potential Implications: The proposal places significant cost-shifting onto textile producers, requiring fashion and home-goods brands to redesign products, internalize waste-management expenses, and adapt supply-chain transparency. Retailers and food-service operators face enhanced reporting and waste-reduction obligations. The EU-wide framework reduces fragmentation across Member States and accelerates investment in textile-sorting and fiber-to-fiber recycling capacity. Food-system actors may face operational changes to meet reduction targets, while households may see consumer-facing waste-prevention programs expand.
Status: Pending. Under consideration by the European Parliament and Council (as of latest available documents).
Introduced: March 22, 2023 by the European Commission
Snapshot: The Green Claims Directive proposal establishes EU-wide rules for how companies substantiate and communicate environmental claims about products and services. It targets misleading environmental marketing and introduces strict substantiation, verification, and labeling requirements. The proposal directly affects retailers, fashion and beauty brands, and consumer-goods companies making sustainability claims in advertising, packaging, and online listings.
Key Provisions: The legislation requires that (1) companies making voluntary environmental claims substantiate them with recognized scientific evidence, life-cycle analysis, and clearly defined methodologies; (2) all environmental claims and sustainability labels undergo independent third-party verification before use; (3) generic environmental claims such as “eco-friendly,” “green,” or “carbon-neutral” be prohibited unless supported by detailed, verifiable evidence; (4) environmental labels be approved under an EU conformity system, with restrictions on new private labels to avoid proliferation and consumer confusion; and (5) claims based on offsets or climate-neutrality mechanisms meet strict transparency requirements, including separate disclosure of emissions reductions vs. purchased offsets.
Potential Implications: Retailers and brands selling into the EU must overhaul sustainability marketing, packaging text, hangtags, website product descriptions, and advertising to meet strict substantiation and verification requirements. Fashion, beauty, home goods, and lifestyle brands face heightened scrutiny of fiber, material, “recycled,” and “carbon-neutral” claims. Online marketplaces will be responsible for ensuring that merchants’ environmental claims comply with verification rules. Failure to comply may result in fines, claim removal orders, and prohibitions on product marketing.
Status: Last update was June 2025 when the proposal was in “deliberations in Coreper” before being introduced to the European Parliament.
Introduced: March 22, 2023 by the European Commission.
Snapshot: Directive (EU) 2024/1799 establishes new EU-wide rules promoting the repair of consumer goods both within and beyond the seller’s legal guarantee period. It requires manufacturers to offer repair services for products covered by EU repairability requirements and enhances consumer rights to choose repair over replacement. Retailers must update after-sales practices, consumer disclosures, and processes for repairs within the legal guarantee.
Key Provisions: The legislation requires that (1) manufacturers repair goods covered by EU repairability rules upon consumer request, even outside the seller’s liability period, and may not refuse repair solely because a product was previously repaired by another provider; (2) sellers inform consumers of their right to choose repair over replacement during the legal guarantee and apply a 12-month extension of the liability period when repair is chosen; (3) repairers, including retailers that offer repair services, provide key pre-contract information using the European Repair Information Form, covering price, turnaround time, and availability of replacement goods; (4) Member States establish a free European online repair platform enabling consumers to locate repair services and refurbished-goods sellers; and (5) spare parts, repair tools, and repair information be made available at reasonable prices to avoid deterring repair.
Potential Implications: Retailers offering repair services must standardize disclosures, honor fixed repair conditions for 30 days, and provide reasonable pricing and timelines. Retailers acting as sellers must notify consumers of their right to choose repair and apply the required warranty extension when repair is selected. Brands and manufacturers selling into the EU must prepare for mandatory repair obligations, ensure availability of spare parts, and publish typical repair-price information. Platforms and marketplaces must avoid misleading practices suggesting that independent repairs void repair options.
Status: Adopted June 2024; Member States must transpose by 31 July 2026, with application beginning on that date.
Introduced: February 6, 2023 by Sen. Pete Harckham (D).
Snapshot: The Packaging Reduction and Recycling Infrastructure Act (S4246) would make New York one of the first states to require producers of packaging and packaged goods to take financial and operational responsibility for the waste they create.
Key Provisions: The bill would require companies to (1) register with a Packaging Reduction and Recycling Organization and submit a plan to reduce packaging waste; (2) meet phased packaging-reduction targets, including cutting plastic packaging by 30 percent over time; (3) fund recycling and reuse infrastructure across the state; (4) eliminate toxic substances such as PFAS and heavy metals from packaging materials; (5) report annually on progress and performance against reduction targets.
Potential Implications: If enacted, the law would shift recycling costs from taxpayers to producers and require brands selling in New York to redesign packaging, reformulate materials, and demonstrate measurable progress toward circularity.
Status: A new version was introduced for the 2025-2026 session (See S1464).
Introduced: September 14, 2022 by the European Commission (as part of the EU’s “Corporate Sustainability” and trade due diligence package).
Snapshot: The regulation aims to prevent forced labor by prohibiting products made with forced labor, mandating European Union member states to establish a competent authority to investigate and penalize distributors and manufacturers who use forced labor.
Key Provisions: The regulation mandates: (1) requires member states to establish their own agencies or authorities that will execute the obligations in the regulation, including forced labor investigations and determinations; (2) the establishment of a database on forced labor risks in specific geographic areas or within specific product groups; (3) that the EU Commission create a guidance for economic operators on due diligence in relation to forced labor; (4) that the EU Commission act as lead competent authority when the suspected forced labor takes place outside of the union; (5) that the competent authority prohibits products that have been determined to be made from forced labor to be exported or imported to the Union; (5) that the competent authority orders distributors or manufacturers to dispose of, remove from online listings, or otherwise remove from the marketplace any product made with forced labor.
Potential Implications: The Regulation signals a major shift toward mandatory human rights due diligence and supply-chain transparency across industries. For fashion and retail companies, it underscores the growing expectation to map supply chains in depth and ensure labor rights compliance at every tier of production.
Status: published in the Official Journal of the European Union on December 12th, 2024.
Introduced: March 31, 2022 by the European Commission.
Snapshot: Directive (EU) 2024/825 introduces new consumer-protection rules aimed at addressing greenwashing, misleading sustainability claims, obsolescence practices, and unclear durability or repair information. It amends the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD), creating new restrictions on environmental marketing and new pre-contract information duties for goods, including fashion, electronics, and home goods sold online or in stores.
Key Provisions: The legislation requires that (1) traders avoid misleading environmental and social claims and provide substantiated, clear, and verifiable information on a product’s environmental or circularity characteristics; (2) generic environmental claims such as “eco-friendly” or “green” be prohibited unless the trader can demonstrate recognised excellent environmental performance relevant to the claim; (3) sustainability labels be used only when based on a certification scheme or established by a public authority; (4) sellers provide pre-contract information on durability, reparability, availability of spare parts, and minimum software-update periods, including displaying harmonised labels and notices where applicable; and (5) traders refrain from practices linked to early obsolescence, such as presenting software updates as necessary when they are not, promoting goods with durability-limiting features, or inducing premature replacement of consumables.
Potential Implications: Retailers, fashion brands, electronics companies, marketplaces, and DTC sellers must review environmental marketing claims, sustainability labels, and website product descriptions to meet stricter rules on green claims. Sellers must communicate durability, repairability, and update-period information before sale, including on e-commerce interfaces. Electronics, wearables, footwear with digital elements, and connected devices face expanded disclosure obligations. Retailers will be required to display harmonised notices about legal guarantees and harmonised labels for commercial guarantees of durability.
Status: Adopted February 2024 and recorded in Official Journal in June 2024. Member States must transpose by March 27, 2026. Application begins September 27, 2026.
Introduced: March 30, 2022 by the European Commission
Snapshot: Regulation (EU) 2024/1781 amends the existing EU framework on market surveillance and product compliance to adapt it to the new Ecodesign for Sustainable Products Regulation (ESPR). It strengthens enforcement mechanisms, expands authorities’ powers, and aligns surveillance rules across the EU to ensure that consumer products sold online or in stores comply with new sustainability, durability, and Digital Product Passport (DPP) requirements.
Key Provisions: The legislation requires that (1) market surveillance authorities enforce ecodesign and Digital Product Passport rules with updated powers to inspect products, request documentation, access digital identifiers, and order corrective actions; (2) online marketplaces and fulfillment service providers cooperate with authorities by removing or disabling access to non-compliant product listings; (3) retailers make only compliant products available to EU consumers and provide authorities with required technical information upon request; (4) products already placed on the market be subject to coordinated compliance checks, including cross-border inspections, sampling, and testing; and (5) Member States establish penalties and corrective measures, including withdrawal, recall, or destruction of non-compliant products, in alignment with ESPR.
Potential Implications: Retailers, brands, and online platforms must ensure that all products placed on the EU market comply with upcoming ESPR product rules and that DPP data is accessible to authorities. Online marketplaces face heightened liability for listings and must respond quickly to enforcement orders. Retailers may experience increased inspections and documentation requests, especially for electronics, textiles, footwear, and home goods that will fall under future ecodesign delegated acts.
Status: Adopted June 2024; applied parallel with the phased implementation of the Ecodesign for Sustainable Products Regulation beginning in 2025.
Introduced: March 30, 2022 by the European Commission
Snapshot: Regulation (EU) 2024/1785 establishes a new ecodesign framework that allows the EU to set product-specific requirements for durability, reparability, recyclability, recycled content, chemical restrictions, environmental impact, and product information. The law applies broadly to consumer products sold in the EU, including apparel, footwear, electronics, home goods, beauty devices, and accessories, and introduces the Digital Product Passport (DPP) as a core disclosure tool.
Key Provisions: The legislation requires that (1) products placed on the EU market meet ecodesign requirements adopted through future delegated acts covering durability, reusability, repairability, recyclability, recycled content, energy use, and environmental impacts; (2) companies provide a Digital Product Passport containing standardized information on materials, sustainability performance, and supply-chain data, accessible via QR code or other digital means; (3) certain product categories comply with new rules restricting the destruction of unsold consumer goods, subject to exemptions for SMEs; (4) retailers and online marketplaces ensure that only compliant products bearing the required passport and disclosures are offered to EU consumers; and (5) Member States conduct market surveillance and impose penalties for non-compliance, including product withdrawal and sales bans.
Potential Implications: Retailers and brands selling into the EU will face sweeping redesign, labeling, and data-reporting obligations once product-specific rules are issued. The DPP requirement will demand robust traceability systems, detailed material documentation, and integration of supplier data. The destruction ban will force shifts in overproduction and inventory practices, particularly in fashion, accessories, and electronics. Online sellers must verify compliance before listing products, increasing operational burdens for marketplaces and dropshippers.
Status: Adopted June 2024; being applied in phases beginning 2025, with product-specific ecodesign and DPP requirements issued through forthcoming delegated acts.
Introduced: November 24, 2021 by Senator Julie Miville-Dechêne (Independent from Quebec).
Snapshot: Bill S-211 enacts the Fighting Against Forced Labour and Child Labour in Supply Chains Act and amends the Customs Tariff. The Act requires certain federal institutions and private-sector entities to report annually on measures taken to prevent and reduce the risk of forced or child labour in their supply chains. It also enables a prohibition on importing goods produced with forced or child labour.
Key Provisions: The Act requires covered institutions and entities to (1) submit annual public reports on steps taken to prevent or mitigate forced or child labour risks in their operations and supply chains (due each year by May 31); (2) describe their structure, policies, due diligence processes, risk assessments, and remediation actions; (3) make reports publicly available, including on their websites; (4) allow inspections by designated officials and comply with corrective orders from the Minister of Public Safety; (5) face penalties (up to $250,000) for false statements or non-compliance; and (6) adhere to a national registry maintained by the Minister, with all reports published online.
Potential Implications: S-211 establishes Canada’s first national supply chain transparency law addressing forced and child labour. It aligns Canada with global human rights due diligence trends, requiring both government and large companies to disclose their efforts and increasing reputational accountability.
Status: Assented (enacted) May 11, 2023. In force since January 1, 2024.
Introduced: November 17, 2021 by the European Commission
Snapshot: Regulation (EU) 2023/1115 establishes mandatory due-diligence requirements for placing or making available certain commodities and derived products on the EU market, including leather, rubber, coffee, cocoa, wood, and cattle-derived goods. Retailers selling these goods in stores or online must ensure that products are deforestation-free, legally produced, and accompanied by an approved due-diligence statement.
Key Provisions: The legislation requires that (1) operators and traders placing products on the EU market ensure that covered goods are deforestation-free, legally produced, and traceable to specific production plots or cattle establishments; (2) companies submit a due-diligence statement to the EU information system before products are first placed on the market; (3) traders—including retailers—maintain records identifying their suppliers and, where relevant, downstream commercial customers for at least five years; (4) retailers only sell products for which a due-diligence statement exists and withdraw goods found to be non-compliant; and (5) Member State authorities enforce compliance through inspections, product seizures, and penalties that may reach up to 4 percent of EU turnover.
Potential Implications: Retailers, fashion brands, luxury houses, and consumer-goods companies selling leather goods, rubber-based products, wood products, or other covered commodities must verify supplier due-diligence statements, maintain traceability documentation, and prepare for supply-chain audits. Companies importing private-label goods face full operator-level obligations, including geolocation traceability and legality assessments. Non-compliance may result in product withdrawal, destruction orders, financial penalties, and temporary market bans.
Status: Adopted May 2023; main obligations apply from 30 December 2024 for large companies and June 2025 for SMEs.
Adopted: April 21, 2021 by the European Commission.
Snapshot: The EU’s Corporate Sustainability Reporting Directive (CSRD) expands and modernizes sustainability disclosure requirements for companies operating in the EU. It requires large companies, listed SMEs, and certain non-EU enterprises to report detailed environmental, human-rights, and supply-chain information. CSRD replaces and significantly broadens the prior Non-Financial Reporting Directive (NFRD), establishing standardized reporting under mandatory European Sustainability Reporting Standards (ESRS).
Key Provisions: The legislation requires that (1) large EU companies and listed SMEs disclose sustainability information in line with ESRS, covering environmental impacts, supply-chain due diligence, workforce issues, and governance; (2) non-EU companies generating more than €150 million in EU turnover and with at least one EU branch or subsidiary also comply; (3) sustainability disclosures be included in the management report and subject to limited assurance by an accredited auditor; (4) companies report on double materiality, describing both how sustainability matters affect the business and how the business affects people and the environment; and (5) phased application begin in 2024–2028, starting with large public-interest companies and expanding to non-EU multinationals.
Potential Implications: Retailers, fashion brands, and consumer-goods companies selling into the EU face sweeping new disclosure requirements around supply-chain practices, climate risks, human-rights impacts, and material sourcing. CSRD forces companies to build audit-ready ESG data systems, map supply-chain risks, and publicly disclose policies, KPIs, and impacts under standardized metrics. Non-EU brands with significant EU revenue must comply even without an EU legal headquarters, reshaping global sustainability reporting expectations.
Status: Adopted in November 2022; in force since January 2023. Reporting obligations phase-in beginning fiscal year 2024 for the largest companies and expand through 2028 to include non-EU enterprises.
Introduced: April 19, 2021 in the Bundestag by the German Federal Government (Bundeskabinett).
Snapshot: Germany’s Supply Chain Act (Lieferkettensorgfaltspflichtengesetz, LkSG) establishes mandatory human rights and environmental due diligence obligations for companies operating in Germany. It marks the first time that corporate accountability for human rights risks throughout global supply chains has been codified in German law.
Key Provisions: The legislation requires that (1) companies with headquarters, principal offices, or branches in Germany establish a risk management system to identify, prevent, and mitigate human rights and environmental risks in their supply chains; (2) due diligence obligations extend beyond a company’s own operations to include direct and indirect suppliers; (3) enterprises with at least 3,000 employees (since 2023) and, from 2024, those with 1,000 or more employees must implement preventive and remedial measures, complaint mechanisms, and annual public reporting; (4) covered risks include child labor, forced labor, unsafe working conditions, denial of collective bargaining rights, inadequate wages, and environmental harm such as land seizure or water deprivation; and (5) violations may result in administrative fines of up to €8 million or up to 2% of annual global turnover, along with exclusion from public contracts for serious breaches.
Potential Implications: Retailers, manufacturers, and consumer-goods companies operating in or selling into Germany face heightened supply chain transparency requirements. Companies must conduct human rights risk assessments, monitor suppliers, and maintain grievance procedures. The law significantly expands corporate liability for abuses within complex international supply networks and serves as a model for forthcoming EU-wide due diligence regulations.
Status: In force since January 1, 2023.
Introduced: March 4, 2021 by the European Commission.
Snapshot: Directive (EU) 2023/970 establishes new EU-wide pay transparency and equal-pay obligations for employers, including retailers, brands, and consumer-goods companies with EU employees. The law introduces mandatory disclosure of pay ranges for job applicants, requires companies to publish gender pay-gap data, and strengthens enforcement mechanisms to address pay discrimination between women and men.
Key Provisions: The legislation requires that (1) employers provide job applicants with the starting pay or pay range for a role and conduct recruitment using gender-neutral job titles and criteria; (2) employers disclose to workers, upon request, their individual pay level and the average pay levels of colleagues performing the same work or work of equal value; (3) companies with 100 or more workers report gender pay-gap data at intervals set by the Directive, with annual reporting for employers with 250 or more workers; (4) employers showing an unexplained gender pay gap of at least 5 percent undertake a joint pay assessment with worker representatives; and (5) Member States provide workers with access to remedies, shift the burden of proof to employers where transparency obligations are unmet, and impose effective penalties for violations.
Potential Implications: Retailers, fashion companies, and consumer-goods brands with EU operations must adjust hiring practices, publish pay-range information, and prepare structured pay-gap disclosures beginning in 2027. The Directive requires detailed pay documentation, gender-neutral pay frameworks, and supply of pay data to employees and regulators. Companies with disparities face mandatory corrective action, potential fines, and heightened litigation risk.
Status: Adopted May 2023; Member States must transpose by June 7, 2026. Employer reporting obligations begin in 2027.
Introduced: January 27, 2021 in the Senate by Sen. Marco Rubio (R–FL) and Senator Jeff Merkley (D–OR).
Snapshot: The Uyghur Forced Labor Prevention Act prohibits the import of goods made wholly or in part in China’s Xinjiang region, where the U.S. government presumes the use of forced labor. In 2024–2025, the Department of Homeland Security expanded enforcement, adding apparel, footwear, and textile manufacturers to the Entity List.
Key Provisions: The law (1) bans all imports tied to Xinjiang unless importers provide “clear and convincing evidence” that no forced labor was involved; (2) mandates public reporting of designated entities using or benefitting from forced labor; (3) authorizes CBP to detain, exclude, or seize shipments; (4) directs companies to implement traceability systems down to the raw material level; and (5) allows DHS to expand the Entity List across sectors, including cotton, yarn, and synthetic fibers.
Potential Implications: Fashion and retail companies face heightened import scrutiny, shipment detentions, and reputational risks. Brands must trace supply chains to the farm or fiber level and document all tiers of production. Non-compliance can result in border seizures, loss of inventory, and regulatory penalties.
Status: Enacted; ongoing enforcement expansion through 2025.