Maintain Compliance
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Compliance
Strategy Guide
The fashion and textile industry is under increasing scrutiny for its environmental and ethical practices. To address this, companies are adopting policies like Extended Producer Responsibility (EPR), Digital Product Passports (DPP), and Circular Product Design. This guide highlights key resources on how to get started and talks about benefits and strategic advantages.
Understanding Extended Producer Responsibility (EPR)
EPR policies require manufacturers to be responsible for the entire lifecycle of their products, especially in terms of their environmental impacts. These policies are designed to promote recycling, reduce waste, and encourage product design changes that minimize environmental impacts.
Current Legislation:
European Union
- EPR Textile Proposal (July 2023): Part of the broader EU efforts under the European Green Deal and the Circular Economy Action Plan
- The proposal aims to make textile producers responsible for the life cycle of their products, including circular design and significant waste reduction.
- March 14, 2024, Legislation Update: The European Parliament voted in favor of revising the Waste Framework Directive for clothing and footwear manufacturers to bear the costs of collecting, transporting, and sorting products for reuse or recycling.
France
- French Circular Economy Law (February 2020)
- Climate and Resilience Law (July 2021)
Netherlands
- Dutch EPR Decree (July 2023): Implements EPR policies specific to the Netherlands, likely targeting a broad spectrum of products to ensure environmental responsibility throughout the product lifecycle.
United States:
Currently, EPR policies are primarily enacted at the state level, with active legislation in key states like California, Colorado, Maine, Minnesota, and Oregon.
California
- SB 707 – Responsible Textile Recovery Act of 2024: Brands will contribute to an EPR program, which will be managed by a network of Producer Responsibility Organizations (PROs) facilitating recycling programs in conjunction with CalRecycle.
- Producer Responsibility Organization (PRO) Membership: Companies must join a PRO, which oversees the collection, sorting, and recycling of textile products.
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- Timeline:
- January 1, 2026 The PRO application is due, with the program expected to be fully operational by January 1, 2031.
- Timeline:
Strategic Benefits:
Customer Engagement through DPPs
Offers consumers detailed product insights, supporting informed and sustainable choices.
Cost Reduction
By designing products for easier recycling or reuse, companies can potentially lower their EPR fees and waste management costs.
DPP Data Management with Texbase:
Detailed Tracking
Texbase offers comprehensive tracking of product materials and lifecycle data.
Communicate EPR Data
Texbase's DPP solution serves as the solution for communicating the data that is necessary for EPR Compliance.
Promotes Circularity
Facilitates sustainable practices by providing material content data & recycling information.
Understanding CPSC eFiling for Imported Consumer Products Compliance
The Consumer Product Safety Commission (CPSC) has introduced an eFiling initiative, requiring importers of regulated consumer products to electronically file data elements from a certificate of compliance. This is done in collaboration with U.S. Customs and Border Protection (CBP) using a Partner Government Agency (PGA) Message Set.
Scope: CPSC eFiling only applies to imported regulated consumer products. Manufacturers who manufacture domestically are not required to eFile product certificates for products produced in the United States.
Required Data Attributes:
The program will require importers of regulated products that require certifications to electronically file data elements at the time of filing an entry including:
identification of the finished product;
party certifying compliance;
each consumer product safety rule to which the finished product has been certified;
date and place the finished product was manufactured;
when and where the finished product was most recently tested for compliance; and
contact information for the person maintaining test records.
source: CPSC eFiling Quick Start Guide
source: link to final ruling
eFiling Timeline/Important Dates: The U.S. Consumer Product Safety Commission (CPSC) has officially published the final rule on eFiling in the Federal Register on January 8, 2025. This is a significant regulatory update impacting businesses across the consumer goods industry.
📅Key Implementation Dates:
July 8, 2026: eFiling requirements take effect for all regulated consumer products (after 18-month transition period).
January 8, 2027: Extended provisions start for products and materials processed through a Foreign Trade Zone, after a 24-month period.
- It should be noted, the CPSC has not set an official date for the rollout and so future dates may be subject to change.
Resources:
Benefits of eFiling
Efficiency in Processing
eFiling allows CPSC to process import shipments more efficiently.
Improved Filing Process
Provides the trade community with an improved, standardized process for electronically filing product certificates.
Focus on Higher Risk Products
Enhances CPSC’s ability to concentrate on products that pose higher risks.
How Texbase Supports CPSC eFiling
Data Integration & Management
Integrates and manages all essential CPSC compliance data including raw materials, testing reports, and supply chain details.
Automated CoC Generation
Automatically generates compliant Certificates of Compliance, reducing manual efforts and minimizing errors.
Secure Data Collaboration
Facilitates secure data exchange with all Tiers of the supply chain and independent labs through Texbase Connect.
Understanding Digital Product Passports (DPP) for Enhanced Product Traceability and Sustainability
Digital Product Passports are part of a broader strategy to enhance the traceability, sustainability, and recycling of products, particularly within the European Union's Circular Economy Action Plan. These passports provide detailed information about product materials, origin, repair, and recycling instructions. DPP serves as the solution for communicating the data that’s necessary for Extended Producer Responsibility compliance.
DPP Framework Update:
On June 28, 2024, the latest Ecodesign Regulation 2024/1781 — which creates a framework for DPPs — was published by the EU. This replaces the previous Ecodesign Directive and will place companies under stricter obligations covering the entire life cycle of a product.
The lastest revision of the Ecodesign for Sustainable Products Regulation (ESPR) is part of the EU's Green Deal, aiming to support a climate-friendly, circular economy.
The new Ecodesign Regulation doesn't specify exact rules for products but sets up a structure for future detailed rules that will apply to specific products from July, 2025.
Manufacturers, importers, and distributors of textile products (including clothes and shoes), should pay attention to upcoming rules as these categories will be the first to be reviewed under the new requirements.
- The regulations listed in the New Ecodesign Regulation 2024/1781 includes the obligation to issue a digital product passport (Art. 9), which – depending on the delegated acts – shall or may include a unique product identifier, the Global Trade Identification Number (GTIN), user manuals, EU declarations of conformity (see Annex III Ecodesign Regulation 2024/1781).
Next Steps:
In December 2025, the European standards organizations CEN/CLC/JTC24 are scheduled to introduce harmonized standards for the DPP system.
| Dates: | Event: |
| December 2025 | CEN/CLC/JTC24 delivers harmonized standards for DPP system |
| January 2026 | Publication of delegated act for textiles |
| April 2026 | Publication of delegated act for iron and steel products |
| July 2027 | Compliance deadline for DPP for textiles in EU |
| October 2027 | Compliance deadline for DPP for iron and steel products in EU |
| February 2027 | Battery Passport regulation takes effect, requiring DPP for transport, industrial, and EV batteries in EU |
* These dates represent projected target deadlines and are subject to changes based on legislative processes and updates in the European Union's regulatory framework.
DPP Data Management with Texbase:
Texbase creates a searchable database of all your products and associated DPP data.
Detailed Tracking
Texbase offers comprehensive tracking of product materials and lifecycle data.
Automatic Supply Chain Mapping
Texbase creates automatic supply chain maps based on the finished product and its components.
Certificate Management & Verification
Texbase serves as a system to manage and present certification data directly to consumers.
Flexible System Architecture
The capability to adapt to various regulatory requirements and customize solutions to align with specific sustainability goals and compliance needs.
Strategic Benefits:
Cost Reduction
By designing products for easier recycling or reuse, companies can potentially lower their EPR fees and waste management costs.
Brand Image
Demonstrating responsibility for product impacts enhances brand reputation and consumer trust.
Customer Engagement
Offers consumers detailed product insights, supporting informed and sustainable choices.
The Loi AGEC, or France’s Anti-Waste and Circular Economy Law, enacted in February 2020, aims to reduce waste and enhance recycling through ambitious targets and sector-wide measures.
Key aspects of the law include:
Extended Producer Responsibility (EPR): Expanding EPR to new product categories requires manufacturers to take more responsibility for end-of-life product management.
Single-use Plastics Ban: Phased bans on single-use plastics, promoting alternatives and reusable products.
Recycling and Reuse Targets: Setting targets for recycling and reuse to reduce single-use product disposal.
Information and Transparency: Requiring producers to provide clear information on product recyclability and environmental impact.
Incentives for Sustainable Practices: Encouraging innovation and sustainable practices through financial incentives and support programs.
The decree mandates that the following information must be:
- Available to the consumer at the point of purchase
- Accessible for data aggregation with other systems
Identify Supply Chain
Data Required: Ensure geographical traceability at the country level for the following manufacturing steps:
- For clothing: manufacturing, dyeing and printing, weaving, and knitting.
- For footwear: finishing, assembling, and stitching.
How Texbase Helps: Texbase supply chain mapping tools allow for the documentation of suppliers participating in a products' value chain.
- Dynamically creates a supply chain map finished product and its components.
- Enables full transparency of the product from raw material sourcing to final production including the Country of each value chain participant.
Identify Hazardous Substances
Data Required:
Every substance labeled as a Substance of Very High Concern (SVHC), under Article 59 of the EU REACH Regulation No. 1907/2006, is classified as hazardous.
- According to the decree and the FAQ section issued in January 2023, there is a grace period until April 1, 2023. Following this period, products must either display the label “contient une substance dangereuse” (contains a hazardous substance). This label should include the names of such substances and is required within six months of their classification as hazardous, provided they constitute at least 0.1% of the product's weight.
How Texbase Helps:
Material libraries for fabric and components track certified materials such as Bluesign or OEKO-TEX® that confirm the materials do not contain harmful chemicals.
- Finished Product certificate management tracks manufacturers that are third party certified such as OEKO-TEX Made In Green.
- For materials that are not third-party certified, Texbase Testing and RSL Guardian along with Texbase Connect capture chemical test results and thereby verify RSL compliance.
Quantify Amount of Recycled Material Content
Data Required: For clothing and footwear items – except leather products –, an indication reading “produit comportant au moins [%] de matériaux recyclés” (product containing at least [%] of recycled material)
How Texbase Helps: Provides a centralized platform to track and report recycled material content.
Communicate Extent of Product Recyclability
Data Required: Include recycling guidelines.
How Texbase Helps:
Texbase captures data for material recyclability & chemical composition, which are essential in determining the extent to which a product can be recycled.
Microplastics
Data Required:
If your material contains more than 50% synthetic fibers by weight, the display must indicate "rejette des microfibres plastiques dans l’environnement lors du lavage" (sheds microplastics into the environment upon washing).
How Texbase Helps: Leveraging the Materials and Testing modules in Texbase allows customers to test materials according to industry standards and determine the presence of microplastics.
Federal Actions:
- The Environmental Protection Agency (EPA) is enhancing regulations, including a recent rule requiring detailed reporting from manufacturers and importers of PFAS dating back to 2011.
Scope of EPA Reporting:
- Applies to PFAS on the EPA’s lists:
- CompTox list
- CDX 8(a)(7) list
- Reporting includes details on PFAS use, production volumes, methods of disposal, exposure scenarios, and associated hazards.
Reporting Timeline:
- The EPA's CDX portal opens for submissions on November 12, 2024.
- Deadline for standard reporting: May 8, 2025.
- Extended deadline for small manufacturers: November 10, 2025.
Current Legislation:
European Union:
- The European Chemicals Agency (ECHA) has detailed the approach of its Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) committees in evaluating the proposal to restrict PFAS in Europe under the REACH regulation.
- After reviewing numerous public comments, these committees will assess the proposed restrictions in sector-specific batches and integrate feedback from the initial report updated by five national authorities, serving as a basis for their forthcoming opinions.
List of State Resources about PFAS:
| Category | Requirement | Proposed Effective Date |
|
Outdoor apparel for severe weather conditions |
Prohibited if intentionally added unless a disclosure ‘Made with PFAS Chemicals’ is added | January 1, 2025 |
|
Medical Floor Maintenance Products, Textile Articles, Commercial Food Equipment |
Prohibited if intentionally added | January 1, 2028 |
Minnesota is implementing PFAS use prohibitions and reporting requirements. Most of these regulations are part of Amara’s Law, which takes effect in stages between January 1, 2025, and January 1, 2032, when sales of products containing intentionally added PFAS will be prohibited in Minnesota, except for those determined to involve currently unavoidable uses of PFAS.
There are some really great resources on the new laws here: https://www.pca.state.mn.us/get-engaged/pfas-in-products
| Category | Requirement | Proposed Effective Date |
| General Apparel | Ban on apparel with intentionally added PFAS. | January 1, 2025 |
| Outdoor Apparel for Severe Wet Conditions | Ban on outdoor apparel for severe wet conditions with intentionally added PFAS. | January 1, 2028 |
| Compliance Certification | Encouragement for brands to maintain compliance certifications from manufacturers to confirm products are PFAS-free. | Ongoing, potential for future audits. |
| Category | Requirement | Proposed Effective Date |
| Textiles and consumer goods | Ban on apprel and other consumer goods with intentionally added PFAS. | January 1, 2025 |
Overview: California’s AB 347 assigns oversight authority for PFAS regulation enforcement to the Department of Toxic Substances Control (DTSC). While it doesn’t introduce new PFAS restrictions, AB 347 ensures stricter regulatory enforcement of existing bans, like those in AB 1817, which prohibit intentionally added PFAS in textiles and other consumer goods.
Compliance Dates:
January 1, 2029: DTSC must have established its enforcement policies for PFAS regulations by this date.
| Category | Requirement | Effective Date | Source |
| General Apparel | Proposed ban on products containing intentionally added PFAS in general apparel. | 2027 (Draft legislation) | https://ecology.wa.gov/blog/september-2024/new-rule-will-reduce-pfas-exposure |
| Category | Requirement | Effective Date |
|---|---|---|
| Carpets and rugs, Cleaning products, Compostable products, Cookware, Cosmetics, Dental floss, Fabric treatments, Food packaging, Intimate apparel, Juvenile products, Menstrual products, Ski wax, Textile furnishings, Upholstered furniture | Prohibited if intentionally added (additional products may be added by rule but effective date must be no earlier than January 1, 2025, and no later than January 1, 2032) |
January 1, 2025 |
| Products | Product manufacturers to submit notification if product contains intentionally added PFAS | January 1, 2026 |
| Products | Prohibited if intentionally added, unless by rule, that the use of PFAS is unavoidable | January 1, 2032 |
PFAS Data Management with Texbase:
Data Centralization
Texbase centralizes all relevant data associated with products, including information on raw materials and product specifications. This helps in organizing and maintaining records that are essential for compliance with PFAS regulatory standards.
Certification Management
Texbase automates the tracking and management of certifications across the product lifecycle and ensures that all certifications are up to date and renewals are managed efficiently. Texbase allows you to manage third-party certificates including communicating certified product data to the end customer through your eCommerce website.
Manage Testing Data
Manage your testing data in one place. This includes organizing tests, lab communication, storing results, and ensuring that products meet the required safety standards before they reach the market.
Document Management
All critical documents related to PFAS compliance, such as certificates of analysis, safety data sheets, and third-party certifications, can be stored and managed within Texbase. This makes it easier to retrieve documents for regulatory reviews or compliance checks.
Disclaimer: The information provided on our website is for informational purposes only and does not constitute legally binding advice or representation.