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: 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: 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: 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: 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: 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.