Fashion and retail have long operated against a relatively light regulatory landscape, particularly in the United States, where many aspects of companies’ operations have historically been governed by a mix of generally applicable laws, voluntary standards, industry initiatives, and self-imposed commitments. That landscape is changing. Lawmakers in the U.S. and abroad are targeting the ways fashion and retail companies make, market, source, sell, and dispose of products, with legislation spanning sustainability, circularity & product regulation; data & retail technology; supply chains, labor & corporate accountability; environmental claims, chemicals & packaging; and trade, imports, manufacturing & anti-counterfeiting.

Against this evolving backdrop, TFL is tracking key retail-related legislation taking shape in the U.S. and internationally, including where these measures currently stand and what they could mean for companies across the industry …

Sustainability, Circularity & Product Regulation

Jul. 29, 2026: Italy – Textile Extended Producer Responsibility Regulation

Status: Draft regulation approved by Italy’s Unified Conference on Jul. 29, 2026.

Snapshot: Italy has moved closer to establishing a national extended producer responsibility (“EPR”) regime for textiles, with the Unified Conference approving a draft regulation presented by the Ministry of Environment and Energy Security. The proposed framework would require manufacturers and certain distributors that first place textile products on the Italian market to assume greater responsibility for managing those products at the end of their useful lives.

Key Provisions: The draft regulation would require covered producers to support or establish systems for the collection of post-consumer textiles and contribute to separate collection and waste-management targets. The framework would also broaden the concept of a producer to include certain importers and distributors placing textile goods on the Italian market for the first time and includes provisions addressing eco-design, recycled materials, traceability, transparency, oversight of collective systems, and online retailers.

Potential Implications: The proposed regime would add another national textile EPR system to the increasingly fragmented European regulatory landscape facing fashion companies. Brands, importers, distributors, and online retailers placing apparel and other textile products on the Italian market could face new financial, reporting, traceability, and end-of-life obligations.

Status: The Unified Conference approved the draft regulation in July 2026. The measure still requires further steps before it becomes binding law.

Sept. 9, 2025: European Union – Waste Framework Directive

Adopted: Sept. 9, 2025 by European Parliament

Snapshot: Introduces 2030 EU food waste reduction targets and mandates extended producer responsibility (“EPR”) schemes for textiles by 2028, as part of a broader effort to reduce waste and advance circularity across the EU.

Key Provisions: The legislation establishes a 30 percent per capita food-waste reduction target by 2030 for retail, restaurants, food services, and households, and a 10 percent reduction target for the manufacturing and processing sector. For textiles, Member States must establish EPR schemes by mid-2028, shifting responsibility for the collection, sorting, reuse, and recycling of textile waste toward producers.

Potential Implications: The textile provisions are particularly significant for fashion brands and retailers, which will increasingly bear financial and operational responsibility for products after they are placed on the market. The framework could affect product design, sourcing, recycling infrastructure, and end-of-life strategies across the industry.

Status: Adopted, with a 30-month transposition period.

Feb. 5, 2025: Rhode Island – Textile Recycling & Education (H 5293 / S 324)

Introduced: Feb. 5, 2025 to the House; Senate companion S 324 followed.

Snapshot: Establishes a statewide public education program on textile recycling through the Rhode Island Department of Environmental Management and the Rhode Island Resource Recovery Corporation.

Key Provisions: The legislation defines covered textiles and requires coordinated public outreach to households and businesses regarding textile diversion, reuse, and proper recycling.

Potential Implications: While narrower than textile EPR regimes emerging in other states, the measure reflects growing state-level attention to textile waste and the development of systems designed to divert apparel and other textiles from landfills.

Status: Signed into law June 23, 2025.

Jan. 24, 2025: New York – Textile EPR (S3217 / A6193)

Introduced: Jan. 24, 2025 to the Senate by Sen. Brian Kavanagh; Feb. 26, 2025 to the Assembly by Assemblymember Anna Kelles.

Snapshot: Would establish an extended producer responsibility program for textiles sold in New York.

Key Provisions: Producers would be required to submit a Department of Environmental Conservation-approved plan for the collection, reuse, recycling, or proper disposal of covered textiles. Producer-funded compliance could be carried out individually, jointly, or through a representative organization, with the legislation establishing program administration and enforcement mechanisms.

Potential Implications: If enacted, the measure would shift greater responsibility for textile waste from consumers and municipalities to fashion brands and other producers, potentially affecting product design, recycling programs, collection systems, and end-of-life costs.

Status: Active in the 2025–26 legislative session.

Jan. 20, 2025: Washington – Textile EPR (HB 1420)

Introduced: Jan. 20, 2025 by Rep. Kristine Reeves.

Snapshot: Would create a statewide producer-responsibility system for textiles, prioritizing reduction, reuse, and recycling.

Key Provisions: Producers would be required to join or establish a Producer Responsibility Organization and participate in a state-approved textile stewardship plan, with implementation overseen by the Washington Department of Ecology.

Potential Implications: The proposal forms part of a broader move toward textile-specific EPR in the U.S., which could require fashion brands to finance and participate in systems for collecting and managing apparel and textiles after consumer use.

Status: Pending.

Sept. 28, 2024: California Responsible Textile Recovery Act (SB 707)

Introduced: Feb. 16, 2023 by Sens. Josh Newman, Nancy Skinner, and Scott Wiener; signed into law Sept. 28, 2024.

Snapshot: The Responsible Textile Recovery Act establishes California’s extended producer responsibility (“EPR”) framework for apparel and textiles, shifting responsibility for the collection, repair, reuse, and recycling of covered textile products toward producers.

Key Provisions: Covered producers must participate in a producer responsibility organization and help finance and implement a statewide system for collecting and managing apparel and textile products after consumer use. The framework prioritizes reuse and repair alongside recycling and gives CalRecycle oversight of the program.

Potential Implications: The law represents the first textile-specific EPR program of its kind in the U.S. and creates significant new end-of-life obligations for apparel and textile companies selling into California. It could also serve as a model for textile EPR proposals emerging in other states.

Status (Feb. 27, 2026): CalRecycle selected Landbell USA to serve as the producer responsibility organization responsible for implementing the law. Producers were required to join the program by July 1, 2026.

Mar. 14, 2024: France – Anti-Fast Fashion Bill (Loi Violland)

Introduced: March 14, 2024, when the French National Assembly approved the bill on first reading following its introduction by MP Anne-Cécile Violland.

Snapshot: The bill seeks to curb the environmental impacts of ultra-fast fashion by targeting companies that rapidly place large volumes of low-cost apparel on the French market. Originally drafted to regulate fast fashion more broadly, the legislation was subsequently narrowed to focus primarily on ultra-fast-fashion platforms.

Key Provisions: The bill establishes a framework for identifying ultra-fast-fashion companies based on factors including the volume of products placed on the market and the relationship between a garment’s purchase price and repairability. It would introduce environmental penalties tied to companies’ environmental performance, with per-item penalties increasing over time to as much as €10 by 2030, subject to a cap of 50 percent of the product’s pre-tax sale price.

The bill would also prohibit advertising by qualifying ultra-fast-fashion companies, including through influencers, and require covered companies to provide consumers with information about the environmental impacts of their products while displaying messages encouraging garment reuse, repair, and more responsible consumption.

Status (Jun. 29, 2026): Approved by both the National Assembly and the Senate and awaiting presidential promulgation and publication.

Mar. 22, 2023: EU Right to Repair Directive (Directive (EU) 2024/1799)

Introduced: March 22, 2023 by the European Commission.

Snapshot: Directive (EU) 2024/1799 establishes EU-wide rules intended to promote the repair of consumer goods both within and beyond the seller’s legal guarantee period, imposing new obligations on manufacturers and expanding consumers’ ability to choose repair over replacement.

Key Provisions: The legislation requires manufacturers to offer repair for products covered by EU repairability requirements under specified circumstances and introduces new consumer information requirements regarding repair. It also establishes measures aimed at making repair services, spare parts, and repair information more accessible.

Potential Implications: The framework adds regulatory support to the broader shift toward repair, refurbishment, and longer product lifecycles. Retailers and brands selling covered products in the EU may need to adapt after-sales services, consumer disclosures, and repair infrastructure.

Status: Adopted June 2024; Member States were required to transpose the Directive by July 31, 2026.

Mar. 30, 2022: EU Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781)

Introduced: March 30, 2022 by the European Commission.

Snapshot: The Ecodesign for Sustainable Products Regulation (“ESPR”) establishes a framework for the EU to impose product-specific sustainability requirements addressing durability, repairability, recyclability, recycled content, chemical substances, environmental impacts, and product information. Textiles and footwear are among the priority product categories.

Key Provisions: The regulation enables the European Commission to establish product-specific ecodesign requirements addressing factors including durability, reusability, repairability, recyclability, recycled content, resource and energy use, and environmental impacts. It also introduces the Digital Product Passport, which will provide standardized product and sustainability information, and establishes restrictions on the destruction of certain unsold consumer goods. 

Potential Implications: For fashion and retail companies, the ESPR represents one of the most consequential components of the EU’s emerging product-sustainability framework. As product-specific rules are adopted, brands may face new requirements around product design, materials, traceability, disclosures, inventory management, and the data that accompanies products throughout their lifecycle.

Status (Jul. 19, 2026): The ESPR was adopted in June 2024 and is being implemented in phases through delegated and implementing acts. On Feb. 9, 2026, the European Commission adopted measures implementing the ESPR’s prohibition on the destruction of unsold apparel, clothing accessories, and footwear and establishing a standardized reporting format for disclosures concerning unsold consumer products discarded as waste. 

The destruction ban took effect for large companies on July 19, 2026, and will apply to medium-sized companies beginning July 19, 2030; micro and small enterprises are exempt. Limited exceptions apply, including for certain damaged, unsafe, counterfeit, and IP-infringing products. Large companies are also subject to disclosure requirements concerning discarded unsold goods.

Data & Retail Technology

Feb. 23, 2022: European Union – Data Act (Regulation (EU) 2023/2854)

Introduced: Feb. 23, 2022 by the European Commission.

Snapshot: The Data Act establishes harmonized EU rules governing access to and use of data generated by connected products and related services. The regulation is designed to give users greater control over data generated through their use of connected products while establishing rules governing data sharing among businesses, consumers, and public authorities.

Key Provisions: The regulation gives users rights to access data generated by connected products and related services and to share that data with third parties; imposes obligations on data holders to make certain data available; restricts certain unfair contractual terms governing data access and use; establishes rules intended to facilitate switching between data-processing and cloud providers; and introduces interoperability requirements for data spaces and data-processing services.

Potential Implications: For fashion and retail companies offering connected products, the Data Act may affect control over product-generated data, relationships with consumers and third-party service providers, aftermarket services, and the design of connected products and related services. Its reach could extend to connected wearables and other digitally enabled consumer products that generate data through their use.

Status: The Data Act entered into force on Jan. 11, 2024 and has applied across the EU since Sept. 12, 2025. The obligation under Article 3(1), which requires connected products and related services to be designed so that product and related-service data are accessible to users in specified circumstances, applies to connected products and related services placed on the market after Sept. 12, 2026. Additional rules governing certain pre-existing contracts apply beginning Sept. 12, 2027.

Supply Chains, Labor & Corporate Accountability

Feb. 4, 2025: California Fashion Environmental Accountability Act (AB 405)

Introduced: Feb. 4, 2025 by Assemblymember Dawn Addis.

Snapshot: The Fashion Environmental Accountability Act would require fashion sellers doing business in California to conduct environmental due diligence across their operations and supply chains and comply with new requirements concerning supplier disclosure, greenhouse-gas emissions, chemicals, wastewater, and other environmental impacts.

Key Provisions: Covered fashion sellers would be required to embed responsible business conduct into their policies and management systems; identify, assess, prevent, and mitigate significant environmental risks; and progressively disclose suppliers across tiers 1 through 4 of their supply chains. The legislation also establishes requirements concerning greenhouse-gas emissions and regulated chemicals in covered fashion products. 

Potential Implications: The bill would create a fashion-specific environmental due-diligence regime in California, requiring covered companies to develop significantly greater visibility into their suppliers, materials, chemical use, emissions, and other environmental impacts.

Status: Pending in the 2025–26 legislative session.

Feb. 4, 2025: New York Fashion Environmental Accountability Act (A.4631-B/S.9740)

Introduced: A.4631 introduced Feb. 4, 2025 by Assemblymember Anna Kelles; current Senate counterpart S.9740 introduced Apr. 2, 2026 by Sen. Brian Kavanagh.

Snapshot: The Fashion Environmental Accountability Act would require large fashion sellers doing business in New York to carry out environmental and social due diligence across their operations and supply chains and publicly disclose information concerning sourcing, emissions, chemicals, labor conditions, and other impacts.

Key Provisions: Covered fashion sellers would be required to map significant portions of their supply chains; identify, prevent, mitigate, and remediate actual and potential environmental and human-rights impacts; establish and report greenhouse-gas reduction targets; address chemical management and wastewater practices at significant tier-two suppliers; and provide specified disclosures concerning labor conditions and wages. The legislation would also establish a Fashion Remediation Fund.

Potential Implications: If enacted, the measure would create one of the most expansive fashion-specific due-diligence regimes in the U.S., moving supply-chain transparency, climate targets, chemical management, and labor accountability beyond voluntary ESG commitments and into a formal compliance framework.

Status: Pending in the 2025–26 legislative session. A.4631-B remains in the Assembly Consumer Affairs and Protection Committee, while S.9740 is pending in the Senate Consumer Protection Committee.

Jan. 17, 2025: Massachusetts – An Act to Establish Environmental Accountability in the Fashion Industry (H.1032)

Introduced: Jan. 17, 2025; an earlier version was introduced in 2023.

Snapshot: H.1032 would establish fashion sustainability and social-accountability requirements by requiring covered fashion sellers and manufacturers to carry out human-rights and environmental due diligence for apparel and footwear products.

Key Provisions: The bill would apply to major fashion companies with more than $100 million in global revenue and require them to map tiers 1 through 4 of their supply chains, including raw-material suppliers, processors, fabric manufacturers, component manufacturers, and finished-product manufacturers. Covered companies would also be required to disclose suppliers and submit due-diligence reports addressing actual and potential adverse impacts in their operations and supply chains.

Potential Implications: The legislation would extend the emerging state-level fashion accountability model to Massachusetts, requiring large fashion companies to undertake formal supply-chain mapping and due diligence rather than relying solely on voluntary sustainability and sourcing programs.

Status: Pending.

Jan. 13, 2025: Washington Fashion Sustainability and Social Accountability Act (HB 1107)

Introduced: Reintroduced Jan. 13, 2025.

Snapshot: HB 1107 would impose new environmental and social-accountability requirements on certain fashion producers and sellers operating in Washington State.

Key Provisions: Beginning in 2027, covered producers would be required to disclose specified environmental impacts associated with their products, including information concerning high-priority chemicals and sustainability-related marketing terms. Producers with more than $100 million in gross income would face additional disclosure requirements concerning environmental due diligence and working conditions. The legislation also establishes civil penalties and a Community Environmental and Public Health Improvement Account funded by penalties.

Potential Implications: The measure would add Washington to the growing number of states considering fashion-specific supply-chain and environmental accountability legislation, increasing the possibility that national brands will face overlapping state disclosure and due-diligence regimes.

Status: Pending.

Dec. 21, 2024: New York Fashion Workers Act (S8638/A9762)

Introduced: March 23, 2022 by State Sen. Brad Hoylman and Assemblymember Karines Reyes; signed into law Dec. 21, 2024.

Snapshot: The New York Fashion Workers Act regulates model management companies and provides new labor protections for models and other fashion-industry creatives, including requirements concerning contracts, compensation, workplace practices, and digital replicas.

Key Provisions: The law establishes duties for model management companies and certain clients, including retail stores, manufacturers, clothing designers, advertising agencies, photographers, and publishing companies that receive modeling services. Among other things, the law addresses payment practices, contracts, management-company registration, and the use of models’ digital replicas.

Potential Implications: The law reaches beyond traditional model management companies to fashion brands, retailers, and other companies that directly engage models and creatives for campaigns, photoshoots, and other commercial work. Its digital-replica provisions are particularly significant as companies increasingly experiment with AI-generated and digitally altered models.

Status (Jun. 19, 2026): The Act’s substantive protections took effect on June 19, 2025, and the one-year registration period for model management companies expired on June 19, 2026.

Sept. 14, 2022: EU Regulation Prohibiting Products Made with Forced Labour (Regulation (EU) 2024/3015)

Introduced: Sept. 14, 2022 by the European Commission.

Snapshot: The regulation prohibits products made with forced labour from being placed or made available on the EU market or exported from the EU, creating a new enforcement framework aimed at preventing goods linked to forced labour from circulating in the European market.

Key Provisions: Member States must designate competent authorities to investigate suspected forced-labour violations, while the European Commission will lead investigations where suspected forced labour occurs outside the EU. Where authorities determine that products were made using forced labour, companies may be ordered to withdraw the products from the market, remove online listings, and dispose of the goods.

Potential Implications: The regulation has significant implications for fashion and retail companies with complex global supply chains, particularly those sourcing apparel, footwear, textiles, and raw materials from jurisdictions associated with heightened forced-labour risks. Companies will face increased pressure to trace products and materials through multiple tiers of their supply chains and maintain sufficient information to respond to regulatory investigations.

Status: Adopted in 2024. The prohibition applies beginning Dec. 14, 2027.

May 12, 2022: Fashioning Accountability and Building Real Institutional Change (“FABRIC”) Act (S.4213/H.R. 8473)

Introduced: May 12, 2022 in the Senate by Sen. Kirsten Gillibrand (D-NY); July 21, 2022 in the House by Rep. Carolyn Maloney.

Snapshot: The FABRIC Act is aimed at strengthening domestic apparel manufacturing and establishing new workplace protections for garment workers by amending the Fair Labor Standards Act.

Key Provisions: The legislation would establish a nationwide garment-industry registry through the Department of Labor, create new wage and recordkeeping requirements, restrict piece-rate compensation, and establish new mechanisms for holding fashion brands and retailers, along with manufacturing partners, accountable for certain workplace wage violations.

Potential Implications: A particularly consequential provision would impose joint and several liability on “brand guarantors” that contract with garment-industry employers, potentially making brands responsible for certain wage violations involving workers employed by suppliers and contractors.

Status: The legislation was reintroduced in September 2023.

Nov. 24, 2021: Canada – Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211)

Introduced: Nov. 24, 2021 by Senator Julie Miville-Dechêne.

Snapshot: The Act requires certain private-sector entities and federal institutions to report annually on the steps they are taking to prevent and reduce the risk of forced and child labour in their operations and supply chains.

Key Provisions: Covered entities must submit annual public reports describing their structure, policies, due-diligence processes, risk assessments, remediation measures, and efforts to address forced- and child-labour risks. Reports must be made publicly available, and companies may face penalties for false statements or non-compliance.

Potential Implications: The law creates a national supply-chain transparency regime with clear relevance for fashion and retail companies sourcing goods and materials through complex global supply chains. It increases pressure on companies to map suppliers, identify labor risks, and publicly account for the steps they are taking to address them.

Status: Assented to May 11, 2023; in force since Jan. 1, 2024.

Nov. 17, 2021: EU Deforestation-Free Products Regulation (Regulation (EU) 2023/1115)

Introduced: Nov. 17, 2021 by the European Commission.

Snapshot: The EU Deforestation-Free Products Regulation (“EUDR”) establishes due-diligence and traceability requirements for specified commodities and derived products placed on or exported from the EU market, including cattle-derived products, rubber, wood, coffee, and cocoa.

Key Provisions: Covered operators and traders must ensure that relevant products are deforestation-free, comply with applicable laws in the country of production, and satisfy traceability requirements. The framework requires due-diligence documentation and, for covered products, information linking commodities to their place of production.

Potential Implications: The regulation is particularly relevant for fashion and luxury companies using leather and rubber, as well as retailers selling other covered goods. Companies may need greater visibility into upstream sourcing, geographic origin, and supplier documentation before covered products can be placed on the EU market.

Status (Jul. 13, 2026): Following a targeted revision adopted in December 2025, the principal obligations are scheduled to apply from Dec. 30, 2026, with an additional six-month period for micro and small operators. In July 2026, the European Commission adopted additional measures updating the product scope and supporting operation of the EUDR information system. 

Apr. 21, 2021: EU Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464)

Introduced: Apr. 21, 2021 by the European Commission.

Snapshot: The Corporate Sustainability Reporting Directive (“CSRD”) establishes standardized sustainability-reporting obligations for companies operating in the EU, requiring covered companies to disclose information about environmental and social impacts, risks, governance, and other sustainability matters.

Key Provisions: Covered companies must report sustainability information under European Sustainability Reporting Standards and address double materiality, including both how sustainability matters affect the business and how the business affects people and the environment. The framework also subjects sustainability reporting to assurance requirements.

Potential Implications: For fashion, retail, and consumer-goods companies, the CSRD requires greater visibility into emissions, supply chains, sourcing, workforce issues, and other sustainability matters and turns information that companies historically disclosed voluntarily into standardized regulatory reporting.

Status (2026): The CSRD entered into force in January 2023, but its scope and implementation have subsequently been revised as part of the EU’s sustainability simplification agenda. In 2026, EU lawmakers approved changes that substantially narrow the universe of companies subject to mandatory sustainability reporting. 

Apr. 19, 2021: German Act on Corporate Due Diligence in Supply Chains

Introduced: Apr. 19, 2021 by the German Federal Government.

Snapshot: Germany’s Supply Chain Act (Lieferkettensorgfaltspflichtengesetz, or “LkSG”) establishes mandatory human-rights and environmental due-diligence obligations for certain companies operating in Germany.

Key Provisions: Covered companies must establish risk-management systems to identify, prevent, and mitigate human-rights and environmental risks across their own operations and supply chains. The law requires preventive and remedial measures, complaint procedures, and reporting and can extend due-diligence obligations beyond direct suppliers in certain circumstances.

Potential Implications: Retailers, manufacturers, and consumer-goods companies operating in Germany may face substantial supplier-monitoring and documentation requirements, particularly where production involves multi-tier global supply chains. The law represents an important shift from voluntary supply-chain standards toward legally enforceable due diligence.

Status: In force since Jan. 1, 2023.

Jan. 27, 2021: Uyghur Forced Labor Prevention Act (UFLPA)

Introduced: Jan. 27, 2021 in the Senate by Sens. Marco Rubio (R-FL) and Jeff Merkley (D-OR).

Snapshot: The Uyghur Forced Labor Prevention Act prohibits the importation of goods made wholly or in part in China’s Xinjiang Uyghur Autonomous Region based on a rebuttable presumption that such goods were produced using forced labor.

Key Provisions: Imports linked to Xinjiang are barred unless importers satisfy the applicable evidentiary standard demonstrating that forced labor was not involved. U.S. Customs and Border Protection may detain, exclude, or seize shipments, while the Department of Homeland Security may identify entities associated with forced labor through the UFLPA Entity List.

Potential Implications: The law is particularly consequential for fashion and retail companies because of Xinjiang’s historical role in global cotton and textile supply chains. Brands and importers may need to trace materials to the raw-material level, maintain detailed supplier documentation, and prepare for customs scrutiny and shipment detentions.

Status: In force, with ongoing enforcement and additions to the UFLPA Entity List.

Jan. 30, 2023: California Climate Corporate Data Accountability Act (SB 253) & Climate-Related Financial Risk Act (SB 261)

Introduced: Jan. 30, 2023 as part of California’s Climate Accountability Package.

Snapshot: California’s SB 253 and SB 261 establish climate-related disclosure requirements for large companies doing business in the state, including fashion, retail, and consumer-goods companies that meet the applicable revenue thresholds.

Key Provisions: SB 253 requires covered companies to publicly disclose greenhouse-gas emissions, including Scope 1, Scope 2, and ultimately Scope 3 emissions, subject to specified assurance requirements. SB 261 requires covered companies to disclose climate-related financial risks and the measures they have adopted to address those risks.

Potential Implications: The laws move climate disclosure beyond voluntary ESG reporting and require large businesses operating in California to develop systems capable of collecting, verifying, and reporting climate and supply-chain data. For fashion and retail companies with complex global sourcing networks, Scope 3 reporting is particularly consequential.

Status: Both laws were signed into law on Oct. 7, 2023, with implementation subsequently subject to regulatory developments and litigation.

Dec. 2020: California Garment Worker Protection Act (SB 62)

Introduced: December 2020; signed into law Sept. 27, 2021.

Snapshot: California’s Garment Worker Protection Act establishes wage and workplace protections for garment workers and expands potential liability for fashion companies that contract for garment manufacturing.

Key Provisions: The law prohibits piece-rate compensation for garment workers except in specified circumstances, establishes new recordkeeping requirements, and creates joint and several liability for certain unpaid wages and related damages among contractors, garment manufacturers, and “brand guarantors.”

Potential Implications: The law is particularly consequential for fashion brands because it reaches beyond the direct employer-employee relationship and can impose liability on companies that contract for garment production. Its joint-liability framework subsequently helped inform proposals such as the federal FABRIC Act.

Status: Enacted; effective Jan. 1, 2022.

Environmental Claims, Chemicals & Packaging

May 2, 2025: Denmark – PFAS Restrictions for Clothing, Footwear & Impregnation Products (BEK No. 464)

Adopted: May 2, 2025 by Denmark’s Ministry of Environment.

Snapshot: Denmark has adopted restrictions on the import and sale to consumers of clothing, footwear, and certain impregnation products containing PFAS.

Key Provisions: The regulation prohibits businesses from importing or selling covered clothing, footwear, and impregnation products where specified fluorine thresholds are met. It includes exemptions for certain personal protective equipment, medical devices, recycled and reused clothing and footwear, and other specified uses. 

Potential Implications: The measure adds another national PFAS regime for fashion and footwear companies operating in Europe and increases the need for brands to track chemical composition, testing, exemptions, and country-specific compliance requirements across the EU market.

Status: Entered into force July 1, 2025; the principal import and sales prohibitions took effect July 1, 2026. Existing business inventories may generally be sold through Jan. 1, 2027.

Feb. 27, 2025: France – PFAS Restrictions for Apparel, Footwear & Textiles (Law No. 2025-188)

Enacted: Feb. 27, 2025.

Snapshot: France’s Law No. 2025-188 establishes phased restrictions on PFAS in a range of consumer products, including clothing textiles and footwear, as part of a broader effort to reduce exposure to per- and polyfluoroalkyl substances.

Key Provisions: Beginning Jan. 1, 2026, the law prohibits the manufacture, import, export, and placing on the market of consumer clothing textiles, footwear, and certain waterproofing products containing PFAS, subject to specified exemptions, including certain protective clothing and footwear. Beginning Jan. 1, 2030, the prohibition expands to textiles more broadly, subject to exemptions for essential uses, certain sovereignty-related applications, and specified industrial technical textiles. Residual concentration thresholds are established by implementing rules. 

Potential Implications: The law creates a significant new chemical-compliance obligation for fashion brands and retailers selling apparel and footwear in France and adds another national PFAS regime to the increasingly fragmented regulatory landscape confronting companies operating across multiple markets.

Status: Enacted; restrictions on covered clothing, footwear, and waterproofing products took effect Jan. 1, 2026. 

Feb. 12, 2025: Voluntary Sustainable Apparel Labeling Act (H.R. 1239)

Introduced: Feb. 12, 2025 by Reps. Sean Casten (D-IL) and María Elvira Salazar (R-FL).

Snapshot: The Voluntary Sustainable Apparel Labeling Act would establish a voluntary labeling program administered by the Environmental Protection Agency, in consultation with the Federal Trade Commission and Department of Agriculture, to provide consumers with standardized sustainability information about apparel.

Key Provisions: Apparel sellers could apply to participate in the program and place an EPA-specified label on qualifying products or packaging. The label would provide numerical information concerning greenhouse-gas emissions associated with the full lifecycle of the apparel product and its inputs, with information subject to verification requirements established by the EPA. The legislation would also establish a program through which participants could make voluntary commitments to reduce lifecycle greenhouse-gas emissions and publicly disclose sustainability information.

Potential Implications: The proposal would create a federally administered framework for communicating apparel sustainability information to consumers, potentially providing brands with a standardized alternative to the growing number of privately developed sustainability labels and environmental claims.

Status: Introduced and referred to the House Committee on Energy and Commerce. 

May 5, 2025: New Jersey – PFAS in Consumer Products Including Apparel (A5600)

Introduced: May 5, 2025 by Assemblymembers David Bailey, Jr. and Verlina Reynolds-Jackson.

Snapshot: A5600 would restrict the sale and distribution of a range of consumer products containing intentionally added per- and polyfluoroalkyl substances (“PFAS”), including apparel and certain outdoor apparel.

Key Provisions: The bill defines covered apparel and establishes phased restrictions on intentionally added PFAS across specified product categories, along with labeling and disclosure requirements and staggered compliance dates.

Potential Implications: If enacted, the legislation would add New Jersey to the growing patchwork of states regulating PFAS in apparel and other consumer products, requiring fashion brands and retailers to obtain greater visibility into chemicals used in fabrics, finishes, coatings, and other product components.

Status: Pending.

Feb. 27, 2025: Minnesota PFAS Product Regulation Amendments (HF1627)

Introduced: Feb. 27, 2025 by Rep. Joshua Heintzeman, with Rep. Jeff Backer as co-author.

Snapshot: HF1627 would amend Minnesota’s existing PFAS product-reporting and prohibition framework by extending certain compliance deadlines, clarifying exemptions, and modifying how PFAS use must be disclosed.

Key Provisions: The bill would delay the deadline for PFAS product reporting from Jan. 1, 2026 to Jan. 1, 2028; establish or extend exemptions for specified commercial, industrial, and other products; and modify definitions and reporting requirements under the state’s existing PFAS framework.

Potential Implications: The measure could provide manufacturers and retailers with additional time to identify PFAS across their supply chains and prepare for Minnesota’s broader restrictions on intentionally added PFAS.

Status: Pending.

Jan. 29, 2025: New Mexico PFAS Protection Act (HB 212)

Introduced: Jan. 29, 2025 by Reps. Joanne Ferrary, Debra Sariñana, Dayan Hochman-Vigil, and Kathleen Cates, and Sen. Jeff Steinborn.

Snapshot: The PFAS Protection Act establishes phased restrictions on consumer products containing intentionally added PFAS across a range of categories.

Key Provisions: Beginning in 2027, the law restricts PFAS in specified products including cookware, food packaging, juvenile products, dental floss, and firefighting foam. Additional categories become subject to restrictions beginning in 2028, followed by a broader prohibition on intentionally added PFAS in non-exempt consumer products beginning in 2032.

Potential Implications: The law adds to the increasingly fragmented state-level PFAS compliance landscape confronting national brands and retailers and increases pressure on companies to identify intentionally added PFAS throughout product and material supply chains.

Status: Enacted March 10, 2025.

Jan. 22, 2025: Nebraska Extended Producer Responsibility and Recycling Reform Act (LB 607)

Introduced: Jan. 22, 2025 by Sen. Eliot Bostar.

Snapshot: LB 607 would establish new producer obligations affecting packaging, paper products, and certain batteries sold in Nebraska.

Key Provisions: The legislation would require producers of packaging and paper products to report annual material volumes and composition; establish stewardship requirements for certain battery producers; and impose minimum post-consumer recycled-content requirements for specified plastic packaging.

Potential Implications: Retailers and consumer-goods brands selling into Nebraska could face new reporting, recycled-content, and supply-chain verification obligations, while producers of certain battery-powered consumer products could become subject to stewardship requirements.

Status: Pending.

Jan. 16, 2025: Massachusetts Packaging Reduction and Recycling Act (S571)

Introduced: Jan. 16, 2025 by Sen. Sal N. DiDomenico.

Snapshot: S571 would create a statewide extended producer responsibility framework for packaging and paper products, shifting responsibility for financing and managing portions of the recycling system to producers.

Key Provisions: Covered producers, including certain brand owners, importers, and franchisors, would be required to participate in a Packaging Reduction Organization. Producer fees would reflect factors including material weight, recyclability, and toxicity, and covered companies would face reporting and recycled-content requirements.

Potential Implications: Retailers, consumer-goods companies, and e-commerce brands selling into Massachusetts could face packaging-design, reporting, and producer-fee obligations.

Status: Pending.

Jan. 2025: New York Packaging Reduction and Recycling Infrastructure Act (S1464/A1749)

Introduced: January 2025.

Snapshot: The Packaging Reduction and Recycling Infrastructure Act would establish an extended producer responsibility framework for packaging in New York, requiring covered producers to participate in a producer organization responsible for developing and implementing a statewide packaging-reduction and recycling program. 

Key Provisions: The legislation would establish packaging-reduction requirements, recycled-content standards, recyclability requirements, and restrictions on certain toxic substances and materials. Covered producers would be required to register with a packaging reduction and recycling organization, which would develop and administer the program under state oversight. 

Potential Implications: The measure would shift more of the cost and responsibility for packaging waste to companies placing packaged products on the New York market, with implications for packaging design, material sourcing, recycling, reporting, and producer fees.

Status (Jun. 2026): S1464 passed the Senate in 2025 but died in the Assembly. The measure remains active in the 2025–26 session as amended S1464A/A1749A. 

Jun. 3, 2024: New Jersey Packaging Product Stewardship Act (S3398)

Introduced: June 3, 2024 by Sens. Bob Smith and Paul D. Moriarty.

Snapshot: The Packaging Product Stewardship Act would establish an extended producer responsibility framework requiring packaging producers to finance and manage the collection, recycling, and reduction of packaging materials.

Key Provisions: Covered producers would be required to join or form a Producer Responsibility Organization or establish an individual stewardship plan. The proposal includes packaging-reduction, recyclability, and recycling targets, along with eco-modulated fees based on factors such as recyclability, toxicity, and material composition.

Potential Implications: If enacted, the measure would require packaging producers, consumer-goods companies, and retailers operating in New Jersey to address product recyclability, packaging reduction, recycled content, and the costs associated with waste-management infrastructure.

Status: Pending.

Feb. 2024: Maryland Packaging and Paper Products Producer Responsibility Act (SB 901)

Introduced: February 2024 by Sen. Malcolm Augustine.

Snapshot: The measure establishes an extended producer responsibility program for packaging and paper products, requiring producers to fund and participate in the collection, reuse, and recycling of covered materials.

Key Provisions: Covered producers must participate in a Producer Responsibility Organization and a state-approved producer responsibility plan. The framework provides for packaging-reduction and recyclability targets, producer fees, and state oversight.

Potential Implications: The framework shifts more of the financial responsibility for packaging waste from local governments to producers, with implications for packaging design, material choices, recycling, and compliance costs for brands selling packaged goods.

Status: Enacted May 9, 2025.

Jan. 29, 2024: Colorado PFAS Consumer Protection Improvement Act (HB24-1148)

Introduced: Jan. 29, 2024 by Sen. Lisa Cutter and Reps. Cathy Kipp and Manny Rutinel.

Snapshot: HB24-1148 expands Colorado’s restrictions on products containing intentionally added PFAS by adding product categories and modifying the state’s existing PFAS regulatory framework.

Key Provisions: The legislation broadens restrictions affecting consumer-product categories including apparel and establishes additional requirements and phaseout dates for products containing intentionally added PFAS.

Potential Implications: Manufacturers, importers, and retailers selling into Colorado need greater visibility into chemical use across product supply chains as the state expands its PFAS restrictions.

Status: Enacted May 1, 2024.

Jan. 2024: Washington Recycling Reform and Packaging Producer Responsibility Act (SB 5284)

Introduced: January 2024.

Snapshot: The measure establishes a statewide framework aimed at shifting greater responsibility for packaging and recycling onto producers.

Key Provisions: The framework includes producer-responsibility requirements, recycling-system reforms, and measures directed at packaging reduction, recycled content, and the management of covered materials.

Potential Implications: Consumer-goods companies and retailers selling packaged products in Washington may face increased responsibility for packaging design, material sourcing, recycling, reporting, and waste-management costs.

Status: Enacted in 2025, with implementation beginning in phases.

Mar. 22, 2023: EU Green Claims Directive Proposal (COM/2023/166)

Introduced: March 22, 2023 by the European Commission.

Snapshot: The Green Claims Directive proposal would establish EU-wide rules governing how companies substantiate and communicate voluntary environmental claims about products and businesses, targeting potentially misleading sustainability marketing.

Key Provisions: The proposal would require companies to substantiate certain environmental claims using specified assessment criteria and would establish requirements concerning verification and environmental labeling schemes.

Potential Implications: For fashion and retail companies, the proposal could significantly affect environmental claims appearing in advertising, packaging, product descriptions, hangtags, websites, and other consumer-facing communications.

Status: Proposed legislation; not yet enacted.

Jan. 11, 2023: New York PFAS Apparel Ban

Introduced: S.1322 introduced Jan. 11, 2023 by Sen. Brad Hoylman-Sigal; underlying PFAS apparel legislation was enacted in December 2022.

Snapshot: New York restricts intentionally added PFAS in apparel, making the state one of a growing number of jurisdictions regulating “forever chemicals” in clothing and other consumer products.

Key Provisions: The law applies broadly to apparel and establishes phased restrictions on intentionally added PFAS, with separate treatment for certain categories of outdoor apparel designed for severe wet conditions.

Potential Implications: Apparel brands, manufacturers, and retailers selling into New York need visibility into chemicals used in fabrics, finishes, coatings, and other components throughout their supply chains.

Status: Restrictions on intentionally added PFAS in apparel took effect Jan. 1, 2025, with additional requirements applying on phased timelines.

Sept. 29, 2022: California PFAS Textile Ban (AB 1817)

Enacted: Sept. 29, 2022.

Snapshot: California’s AB 1817 restricts PFAS in new textile articles sold or distributed in the state, including apparel, accessories, footwear, and other textile products.

Key Provisions: Beginning Jan. 1, 2025, the law prohibits the manufacture, distribution, sale, or offer for sale of new textile articles containing regulated PFAS, subject to specified exceptions. Manufacturers must also provide sellers and distributors with certificates of compliance and use the least toxic alternative when replacing regulated PFAS. 

Potential Implications: The law creates direct product-composition and supply-chain documentation obligations for fashion brands and retailers selling into California and sits alongside New York and other state PFAS restrictions in creating an increasingly fragmented U.S. compliance landscape.

Status: Enacted; restrictions took effect Jan. 1, 2025. 

Mar. 31, 2022: EU Empowering Consumers for the Green Transition Directive (Directive (EU) 2024/825)

Introduced: March 31, 2022 by the European Commission.

Snapshot: Directive (EU) 2024/825 introduces consumer-protection rules aimed at greenwashing, misleading sustainability claims, obsolescence practices, and unclear durability and repair information.

Key Provisions: The legislation restricts generic environmental claims such as “green” and “environmentally friendly” unless applicable requirements are satisfied; limits the use of sustainability labels; targets certain misleading claims concerning durability and repairability; and introduces new consumer-information requirements.

Potential Implications: Fashion brands and retailers selling into the EU will need to reassess environmental marketing claims, sustainability labels, product descriptions, websites, and other consumer-facing communications. The Directive moves a range of sustainability claims from voluntary marketing territory into a more prescriptive consumer-protection framework.

Status: Adopted in February 2024. Member States were required to transpose the Directive by March 27, 2026, with the new rules applying beginning Sept. 27, 2026.

Oct. 5, 2021: California Truth in Recycling Law (SB 343)

Introduced: Feb. 4, 2021 by Sen. Ben Allen; enacted Oct. 5, 2021.

Snapshot: California’s SB 343 restricts use of the “chasing arrows” recycling symbol and other recyclability claims on products and packaging in an effort to prevent companies from marketing materials as recyclable where California’s recycling system does not actually support those claims.

Key Provisions: The law generally restricts recyclability representations to products and packaging that satisfy specified statutory criteria tied to collection, sorting, and processing within California. CalRecycle is tasked with identifying which materials are actually recycled in the state.

Potential Implications: The law could reshape packaging and environmental marketing practices beyond California because many brands use uniform packaging nationwide. It also illustrates the increasingly close relationship between sustainability regulation and traditional advertising and consumer-protection law.

Status (Jul. 14, 2026): The law is slated to apply to products and packaging manufactured on or after Oct. 4, 2026. Enforcement is currently subject to a preliminary injunction in California League of Food Producers v. Bonta.

Trade, Imports, Manufacturing & Anti-Counterfeiting

Apr. 27, 2026: Counterfeit Notification Act (H.R. 4930)

Adopted: April 27, 2026 by the U.S. House of Representatives.

Introduced by: Reps. Blake Moore (R-UT) and Brad Schneider (D-IL).

Snapshot: The Counterfeit Notification Act expands the authority of U.S. Customs and Border Protection (“CBP”) to share information concerning suspected counterfeit shipments with intellectual property owners, logistics carriers, and e-commerce platforms in an effort to identify and intercept counterfeit goods earlier in the supply chain.

Key Provisions: The bill authorizes CBP to disclose previously restricted information tied to suspected counterfeit shipments, including shipping labels, tracking information, sender and recipient addresses, invoices, manifests, and images of outer packaging. It also broadens the parties eligible to receive that information to include carriers and online platforms, enabling greater coordination among customs officials, rights holders, logistics providers, and marketplaces.

Potential Implications: The measure could give brands and platforms greater visibility into the networks used to distribute counterfeit goods and allow enforcement efforts to move further upstream, rather than relying primarily on seizures after suspicious shipments reach U.S. ports.

Status: Passed the House on April 27, 2026; awaiting consideration in the Senate.

Jan. 22, 2026: Buying American Cotton Act of 2026 (H.R. 7230)

Introduced: Jan. 22, 2026 by Rep. Greg Murphy (R-NC), with bipartisan co-sponsors.

Snapshot: The Buying American Cotton Act would establish a federal tax credit aimed at increasing domestic consumption of U.S.-grown cotton and encouraging greater use of American cotton throughout textile and apparel supply chains.

Key Provisions: The bill would establish a Domestic Cotton Consumption Credit based on the volume of U.S.-origin cotton used in qualifying consumer articles. It provides enhanced credits for certain cotton yarn and fabric manufactured in the U.S. and requires digital tracing and certification systems designed to verify the origin of eligible cotton.

Potential Implications: The proposal could create new financial incentives for apparel and textile companies to source U.S.-grown cotton and invest in domestic manufacturing while also increasing pressure for greater cotton traceability throughout the supply chain.

Status: Pending.

Mar. 4, 2025: Closing the De Minimis Loophole Act (H.R. 1840 / S. 1867)

Introduced: H.R. 1840 introduced March 4, 2025 by Rep. Linda T. Sánchez; S. 1867 introduced May 22, 2025 by Sens. Sheldon Whitehouse and Lindsey Graham.

Snapshot: The Closing the De Minimis Loophole Act would restrict or eliminate duty-free treatment for certain low-value imports entering the U.S. under the de minimis provision of the Tariff Act of 1930.

Key Provisions: The legislation would phase out or terminate specified de minimis treatment and direct CBP to implement additional rules, data requirements, and enforcement mechanisms governing low-value shipments.

Potential Implications: The proposal is particularly relevant to direct-to-consumer retail models built around large volumes of low-value shipments, including ultra-fast-fashion and e-commerce companies that historically relied heavily on the de minimis channel to reach U.S. consumers.

Status: Pending. The broader de minimis landscape has changed substantially since the legislation was introduced, with the executive branch subsequently suspending duty-free de minimis treatment for covered low-value imports.

Mar. 6, 2024: Americas Trade and Investment Act

Introduced: March 6, 2024 by Sens. Bill Cassidy (R-LA) and Michael Bennet (D-CO).

Snapshot: The Americas Trade and Investment Act is aimed at encouraging reshoring and nearshoring from China and includes significant provisions directed at apparel, footwear, accessories, manufacturing, recycling, and trade.

Key Provisions: Apparel and textile provisions include a 15 percent net income exclusion for businesses engaged in collecting, reselling, reusing, renting, repairing, sorting, pre-processing, and recycling apparel, footwear, accessories, and home linens. The legislation also provides for billions of dollars in loans and grants for manufacturing, reuse, recycling, infrastructure, and related programs, along with funding for research, innovation, and public education.

The bill also includes provisions addressing de minimis treatment, forced labor, and incentives for moving production and sourcing closer to the U.S.

Potential Implications: The legislation could affect sourcing and manufacturing strategies across the apparel industry by encouraging regional production and textile circularity while reducing some of the advantages historically associated with direct-to-consumer imports from China.

Status: Pending. Subsequent changes to U.S. de minimis policy have altered part of the trade landscape that the bill was originally designed to address.

Jun. 15, 2023: Import Security and Fairness Act (S.2004)

Introduced: June 15, 2023 by Sens. Sherrod Brown (D-OH) and Marco Rubio (R-FL).

Snapshot: The Import Security and Fairness Act would amend the Tariff Act of 1930 to restrict de minimis treatment for low-value imports from certain countries, including non-market economies such as China.

Key Provisions: The bill would prevent qualifying shipments from certain countries from entering the U.S. duty-free under the de minimis provision and would increase customs scrutiny of low-value imports.

Potential Implications: The proposal was particularly relevant to the rapid growth of direct-to-consumer imports from China, including shipments by ultra-fast-fashion and e-commerce companies. By limiting access to de minimis treatment, the measure could have increased duties and customs requirements for low-value shipments entering the U.S.

Status: Introduced and referred to committee in the 118th Congress; no further action and the bill expired at the end of the session.

Jun. 14, 2023: De Minimis Reciprocity Act of 2023 (S.1969)

Introduced: June 14, 2023 by Sens. Bill Cassidy (R-LA) and Tammy Baldwin (D-WI).

Snapshot: The De Minimis Reciprocity Act would amend the Tariff Act of 1930 to impose greater reciprocity on low-value imports, including by restricting access to the de minimis channel for certain countries and reducing the U.S. duty-free threshold in specified circumstances.

Key Provisions: The bill would exclude certain countries from using the de minimis channel, restrict which carriers may facilitate qualifying shipments, require additional information about packages entering the U.S., and direct certain resulting revenues toward efforts to reshore industry from China.

Potential Implications: The measure was aimed at increasing scrutiny of low-value imports and reducing what lawmakers characterized as an unfair competitive advantage for overseas sellers. For fashion and retail, it carried particular implications for companies relying heavily on direct-to-consumer shipments from China.

Status: Introduced and referred to committee in the 118th Congress; no further action and the bill expired at the end of the session.

May 2021: Stopping Harmful Offers on Platforms by Screening Against Fakes in E-Commerce (“SHOP SAFE”) Act

Introduced: May 2021 by the House Judiciary Committee following an earlier version introduced in 2020.

Snapshot: The SHOP SAFE Act would create potential trademark liability for e-commerce platforms when third-party sellers offer counterfeit products that pose health or safety risks and the platform has failed to implement specified anti-counterfeiting practices.

Key Provisions: The bill would require brand owners to provide platforms with notice of relevant trademarks and contact information while providing a safe harbor for platforms that adopt specified measures, including vetting sellers, removing counterfeit listings, and terminating repeat offenders.

Potential Implications: The proposal would increase incentives for online marketplaces to play a more active role in anti-counterfeiting enforcement and could alter the allocation of responsibility among brands, platforms, and third-party merchants when counterfeit goods are offered online.

Status: Reintroduced on Sept. 26, 2023 by Sens. Chris Coons (D-DE) and Thom Tillis (R-NC).