Report on the Evolving Regulatory Landscape for the Apparel and Textiles Industry and its Alignment with Sustainable Development Goals

Introduction

The legal and regulatory framework governing the apparel and textiles industry is undergoing a significant transformation, driven by a global emphasis on sustainability and environmental stewardship. This shift necessitates a comprehensive understanding of product materials and supply chain specifics to ensure compliance with state, federal, and international regulations. This report outlines key regulatory challenges and their direct correlation with the United Nations Sustainable Development Goals (SDGs), providing a compliance roadmap for manufacturers, distributors, and retailers.

Key Regulatory Areas and SDG Implications

Legal and sustainability professionals in the sector must navigate five critical areas to address compliance and mitigate risk across the supply chain. Each area is intrinsically linked to specific SDGs, highlighting the industry’s role in achieving global sustainability targets.

1. Extended Producer Responsibility (EPR)
2. Environmental Marketing Claims & Litigation Risk
3. Environmental, Social, & Governance (ESG)
4. Per-and Polyfluoroalkyl substances (PFAS)
5. California Proposition 65 (Prop 65)

1. Extended Producer Responsibility (EPR) and SDG 12

EPR frameworks implement circular economy principles, directly supporting SDG 12: Responsible Consumption and Production, particularly Target 12.5, which aims to substantially reduce waste generation. These laws assign producers—typically brand owners, manufacturers, or importers—financial and operational responsibility for the end-of-life management of their products.

Packaging EPR

• As of May 2025, seven U.S. states (California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington) have enacted packaging EPR programs.
• These laws require producers to finance the collection, sorting, and recycling of packaging waste, often by joining and paying fees to a Producer Responsibility Organization (PRO).
• Obligations vary by state regarding reporting deadlines, exemptions, and fee structures, impacting nearly all companies placing packaged goods, including apparel, into the U.S. market.

California Textile EPR

• California’s Responsible Textile Recovery Act represents the first statewide textile EPR program in the U.S.
• Producers selling apparel or textiles in California must join an approved PRO by July 1, 2026.
• The PRO will establish and fund a statewide plan for managing textile waste. Non-compliance can result in penalties of up to $50,000 per day.

2. Environmental Marketing Claims & Litigation Risk and SDG 12

The accuracy and substantiation of environmental marketing claims are under intense scrutiny, aligning with SDG 12: Responsible Consumption and Production, specifically Target 12.8, which focuses on ensuring consumers have the information necessary for sustainable lifestyles. Misleading claims, or “greenwashing,” pose significant litigation risks.

U.S. Litigation Risks

• The Federal Trade Commission (FTC) Act and the FTC’s “Green Guides” regulate environmental claims.
• Litigation from the FTC, state Attorneys General, and private class actions targets false or misleading claims about biodegradability, recycled content, and chemical content (e.g., “PFAS-free”).
• Companies must ensure claims are narrowly tailored and supported by robust evidence to mitigate risk.

International Scrutiny

• European Union: The Empowering Consumers for the Green Transition Directive (ECD), effective from March 2024, prohibits generic environmental claims without substantiation and claims based on carbon offsetting outside the product’s value chain.
• Canada: Amendments to the Competition Act have increased the ability for private parties to challenge misleading environmental claims.
• United Kingdom: The Competition and Markets Authority (CMA) has issued a compliance guide for fashion brands and can now fine businesses up to 10% of global turnover for consumer law violations.

3. Environmental, Social, & Governance (ESG) Frameworks

ESG reporting and due diligence requirements are becoming mandatory, standardizing disclosures on climate risks, sustainability efforts, and human rights. These regulations support multiple SDGs, including SDG 13 (Climate Action), SDG 8 (Decent Work and Economic Growth), and SDG 16 (Peace, Justice and Strong Institutions).

Climate-related Reporting and SDG 13

• Mandatory reporting frameworks like the EU’s Corporate Sustainability Reporting Directive (CSRD) and California’s SB 253 (GHG emissions) and SB 261 (climate-related financial risk) require companies to disclose their climate impact. This directly supports SDG 13: Climate Action.
• Companies operating in California that meet revenue thresholds will face reporting requirements beginning in 2026.

Supply Chain Due Diligence (SDG 8 & SDG 16)

• The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) requires in-scope companies to identify and address adverse environmental and human rights impacts in their supply chains, advancing SDG 8 and SDG 16.
• The EU Forced Labor Prohibition Regulation and the U.S. Uyghur Forced Labor Prevention Act (UFLPA) mandate due diligence to prevent forced labor in supply chains.
• Proposed legislation in New York would require fashion sellers to conduct extensive environmental due diligence and map supply chains from tier one to tier four suppliers.

Modern Slavery Reporting Laws (SDG 8)

• Legislation in California, Canada, the UK, and Australia requires large companies to report on their efforts to identify and eradicate modern slavery and human trafficking from their supply chains, a key component of SDG 8: Decent Work and Economic Growth (Target 8.7).

4. Regulation of Per-and Polyfluoroalkyl Substances (PFAS) and SDGs 3, 6, & 12

Growing restrictions on PFAS in apparel address their environmental and health risks, aligning with SDG 12 (Target 12.4 on sound management of chemicals), SDG 3: Good Health and Well-being (Target 3.9 on reducing illness from hazardous chemicals), and SDG 6: Clean Water and Sanitation (Target 6.3 on reducing pollution).

U.S. Regulations

• At least 11 states have passed laws restricting or requiring reporting of “intentionally added” PFAS in apparel and textiles.
• California will ban textile articles containing PFAS above 100 ppm starting January 1, 2025. New York has also implemented a ban.
• State laws vary significantly in scope, thresholds, and implementation dates, requiring careful tracking by industry participants.

European Union Regulations

• Under REACH, numerous PFAS are listed as Substances of Very High Concern (SVHC), restricting their content in products to 0.1% by weight or requiring notification.
• A broad EU proposal aims to restrict over 10,000 PFAS, with a final decision expected in 2025 or 2026.
• Individual member states, including France and Denmark, are implementing national bans on PFAS in clothing ahead of the broader EU restriction.

5. California Proposition 65 and Chemical Safety (SDG 3 & 12)

Proposition 65 mandates consumer warnings for exposure to nearly 900 chemicals known to cause cancer or reproductive toxicity. This regulation supports SDG 3: Good Health and Well-being and SDG 12: Responsible Consumption and Production by promoting chemical safety and consumer awareness.

Core Requirements and Recent Developments

• Apparel or accessories sold in California containing listed chemicals above safe harbor levels must carry a “clear and reasonable” warning.
• Vinyl acetate, used in textile fiber production, was recently added to the Prop 65 list, with a warning requirement effective December 29, 2025.
• As no safe harbor level has been set for vinyl acetate, the detection of any amount in a product could trigger a notice of violation, placing the burden of proof on the business to demonstrate a lack of significant risk.

1. Which SDGs are addressed or connected to the issues highlighted in the article?

• SDG 8: Decent Work and Economic Growth

  The article discusses regulations aimed at combating forced labor and modern slavery in supply chains, such as the Uyghur Forced Labor Prevention Act (UFLPA) and various Modern Slavery Reporting Laws. These initiatives directly support the goal of promoting sustained, inclusive, and sustainable economic growth, full and productive employment, and decent work for all.

• SDG 12: Responsible Consumption and Production

  This is the most prominent SDG in the article. It is addressed through multiple themes: the implementation of Extended Producer Responsibility (EPR) laws to manage product end-of-life, the regulation of hazardous chemicals like PFAS and those listed under Prop 65, the push for accurate environmental marketing claims to inform consumers, and corporate sustainability reporting (ESG) to encourage sustainable practices.

• SDG 13: Climate Action

  The article connects to this goal through its discussion of Environmental, Social, & Governance (ESG) reporting requirements. Specifically, it mentions California’s climate disclosure rules (SB 253 and SB 261) that mandate reporting on Greenhouse Gas (GHG) emissions and climate-related financial risks, which are direct actions to combat climate change and its impacts.

2. What specific targets under those SDGs can be identified based on the article’s content?

• SDG 8: Decent Work and Economic Growth

  • Target 8.7: Take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking and secure the prohibition and elimination of the worst forms of child labour, including recruitment and use of child soldiers, and by 2025 end child labour in all its forms.

    The article directly relates to this target by detailing various laws that compel companies to address forced labor. It mentions the EU Forced Labor Prohibition Regulation, the U.S. Uyghur Forced Labor Prevention Act (UFLPA), and Modern Slavery Reporting Laws in California, Canada, Australia, and the UK, all of which require companies to identify and mitigate human rights and modern slavery risks in their supply chains.

• SDG 12: Responsible Consumption and Production

  • Target 12.4: By 2020, achieve the environmentally sound management of chemicals and all wastes throughout their life cycle, in accordance with agreed international frameworks, and significantly reduce their release to air, water and soil in order to minimize their adverse impacts on human health and the environment.

    This target is addressed by the extensive discussion on regulating chemicals in textiles. The article highlights restrictions on Per-and Polyfluoroalkyl substances (PFAS) in the U.S. and EU, including specific concentration limits (e.g., California’s 100 ppm threshold). It also covers California’s Proposition 65, which requires warnings for products containing chemicals known to cause cancer or reproductive toxicity, such as vinyl acetate used in textile fibers.

  • Target 12.5: By 2030, substantially reduce waste generation through prevention, reduction, recycling and reuse.

    The concept of Extended Producer Responsibility (EPR), a central theme of the article, directly supports this target. The article explains how packaging and textile EPR laws in California, Colorado, Maine, and other jurisdictions assign producers the financial and operational responsibility for the end-of-life management of their products, thereby promoting a circular economy and reducing waste.

  • Target 12.6: Encourage companies, especially large and transnational companies, to adopt sustainable practices and to integrate sustainability information into their reporting cycle.

    The article’s section on ESG highlights this target. It details the rise of mandatory sustainability and climate-related reporting frameworks like the EU’s Corporate Sustainability Reporting Directive (CSRD) and California’s climate disclosure rules (SB 253 and SB 261). These regulations require companies to measure and disclose their GHG emissions, sustainability efforts, and climate-related risks, compelling them to integrate sustainability into their core operations.

  • Target 12.8: By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development and lifestyles in harmony with nature.

    The section on “Environmental Marketing Claims & Litigation Risk” directly aligns with this target. The article discusses regulations like the FTC’s Green Guides, the EU’s Empowering Consumers for the Green Transition Directive (ECD), and the UK’s Green Claims Code, which are all designed to ensure that companies provide accurate, substantiated, and non-misleading information about the environmental benefits of their products, thereby empowering consumers to make sustainable choices.

• SDG 13: Climate Action

  • Target 13.2: Integrate climate change measures into national policies, strategies and planning.

    While the article focuses on corporate compliance, the state-level policies it describes, such as California’s SB 253 (GHG emissions reporting) and SB 261 (climate-related financial risk reporting), are examples of sub-national governments integrating climate change measures into their regulatory frameworks, which in turn forces companies to act.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

• For Target 8.7 (End Forced Labour)

  • Existence of and compliance with modern slavery reporting laws:

    The article mentions specific laws like the California Transparency in Supply Chains Act and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act. The number of companies subject to these laws that publish the required annual statements can be used as an indicator of progress.

• For Target 12.4 (Sound Management of Chemicals)

  • Concentration limits for specific chemicals:

    The article specifies quantitative limits, such as California’s prohibition on textile articles containing PFAS above 100 parts per million (ppm) and the EU REACH limit of 0.1% by weight for Substances of Very High Concern (SVHC). These thresholds are direct, measurable indicators.

  • Number of regulated substances:

    The article notes that California’s Prop 65 list includes “nearly 900 chemicals” and that the EU is proposing a restriction on “over 10,000 PFAS.” The number of chemicals regulated is an indicator of the scope of action.

• For Target 12.5 (Reduce Waste Generation)

  • Implementation of EPR programs:

    The article states that “California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington have enacted packaging EPR programs.” The number of jurisdictions with such laws is a clear indicator of the adoption of circular economy principles.

  • Amount of packaging material reported:

    The article mentions that under EPR frameworks, “Producers must report the packaging material they introduce into the state by weight.” This reported weight is a direct quantitative indicator for tracking waste generation.

• For Target 12.6 (Corporate Sustainability Reporting)

  • Number of companies required to report:

    The article specifies that disclosure rules like California’s SB 253 and SB 261 apply to corporations that “meet certain revenue thresholds.” The number of companies falling under these mandates and submitting reports is a key indicator.

  • Public disclosure of supply chain mapping:

    Proposed legislation in New York would require fashion sellers to map their supply chain and make reports “publicly accessible.” The availability and comprehensiveness of these public reports would serve as an indicator of transparency and due diligence.

• For Target 13.2 (Integrate Climate Measures)

  • Mandatory reporting of GHG emissions:

    The article highlights California’s SB 253, which mandates GHG emissions reporting. The collected emissions data from companies is a direct indicator for tracking progress on climate action at a corporate and regional level.

4. Table of SDGs, Targets, and Indicators

Source: natlawreview.com