When federal rulemaking stalls, states move and in fashion, they’re moving fast. California, New York, Washington and Massachusetts are each pushing “fashion accountability” bills that would make emissions disclosure, supply-chain mapping, and truth-in-marketing enforceable, not optional.
California’s proposal, AB 405, sets the tone: it captures “fashion sellers” with more than $100 million in annual gross receipts and allows civil penalties up to 2% of annual revenue for non-compliance, alongside chemical controls and due-diligence obligations. If passed, it would be the first U.S. law to pair climate and chemical oversight with brand-level accountability in fashion.
From “We Promise” to “We Must”
This state-level push follows a global turn from voluntary ESG to binding due diligence. The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) entered into force in July 2024, requiring large companies to identify, prevent, and mitigate human-rights and environmental harm across value chains, rules EU countries must transpose by mid-2026. France’s 2017 Duty of Vigilance law already compels the largest companies to publish and implement annual “vigilance plans,” and litigation under that statute is maturing.
The Four-State Shift
-
California (AB 405- Fashion Environmental Accountability Act of 2025).
AB 405 defines “fashion sellers,” sets an Environmental Due Diligence Report starting 2027, requires establishing baselines and targets for Scope 1-3 emissions, folds fashion sellers into California’s broader GHG disclosure regime, and tasks the Department of Toxic Substances Control with chemical thresholds. Penalties can reach 2% of annual revenue; administrative fines apply for certain violations. The bill has advanced through policy committees and is drawing robust industry response. -
New York (Fashion Sustainability and Social Accountability Act- Revival).
Albany’s Fashion Act first introduced in 2022 and refiled in 2025, remains “in review,” but its frame is unchanged: supply-chain mapping (often described through tiers), public due-diligence reporting, and science-based climate targets for brands wishing to sell in New York. New bill numbers this session include A4631/S4558; deliberations continue. New York’s separate Fashion Workers Act is already law, reinforcing the state’s appetite for sector-specific regulation. -
Washington (HB 1107- Environmental Impacts of Fashion).
Olympia’s bill requires disclosures beginning 2027, including any sustainability-related marketing terms used: “sustainable,” “green,” “low impact,” “environmentally friendly”, and how the company defines them. It adds reporting on excess goods disposal and, for companies above $100 million in revenue, due-diligence policies, GHG methods, recycled content, and working-conditions snapshots. It also directs the Department of Ecology to study extended producer responsibility and labeling standards. In short: greenwashing claims meet enforceable definitions. -
Massachusetts (H.1032- Fashion Environmental Accountability).
Boston’s version borrows heavily from New York’s architecture: supplier mapping through deeper tiers, due-diligence reporting, and accountability mechanisms tied to environmental impact and waste, signaling New England’s interest in addressing overproduction and textile waste within a legal framework. A hearing was scheduled this summer as the bill moved into committee review.
Why It Matters
For brands, these bills convert climate and social claims into auditable obligations. California’s text links fashion sellers to the state’s GHG disclosure framework and adds chemical compliance; Washington puts marketing language under a microscope and asks for methods, not slogans; New York and Massachusetts emphasize supplier mapping and climate targets. Law firms advising retailers are already flagging the convergence: emissions baselines and targets, product-chemical thresholds, and supply-chain documentation are becoming a single compliance stack. Trade associations, meanwhile, warn of overlapping mandates (e.g., California’s textile recovery law) and want clearer harmonization, evidence that rulemaking is getting specific enough to bite.
For suppliers, the shift is equally significant. Disclosure pressure moves downstream: mills, dye houses, trim makers, tanneries, and logistics providers will be asked for facility-level data (energy, water, wastewater testing, chemical inventories), chain-of-custody proofs, and corrective-action evidence. Suppliers who can surface verified data quickly will win work faster and retain it longer as brands prune high-risk relationships.
The Report Says
Trade and business coverage has tracked two themes. One of them is the state-by-state approach mirrors Europe’s multi-jurisdiction model, forcing companies to build systems robust enough to satisfy the strictest rule. The other is enforcement teeth, revenue-based fines and public reporting, and change incentives. California’s AB 405 has been profiled as the most comprehensive to date; Washington’s HB 1107 has been framed as a “Fashion Act” reboot focused on disclosures and anti-greenwashing clarity; and New York’s Fashion Act remains a bellwether even without passage, shaping proposals elsewhere.
Digital Traceability is the Enabler
The practical through-line in all four states is data: product-level impact, supplier-level identity, and verifiable claims. That’s precisely where digital tools matter.
-
Supplier mapping & chain-of-custody: You need a live roster of tier-1 to tier-4 suppliers, with certificates, locations, and materials linked to finished SKUs.
-
Impact data at product level: Life-cycle metrics (CO₂e, water, chemicals) tied to each style or material, not just corporate averages.
-
Claim substantiation: If you say “recycled,” “low-impact,” or “climate-neutral,” Washington wants your definitions and methods. Keep those references, test reports, and allocation methodologies audit-ready.
The Global Context
Expect a feedback loop. As the EU’s CSDDD rolls into national laws, U.S. brands selling in Europe will upgrade due-diligence systems. As U.S. states adopt fashion-specific rules, those same systems will be repurposed domestically. The result isn’t a patchwork so much as a ratchet: once a brand builds end-to-end traceability and product-level impact reporting to meet the strictest standard, it will use that infrastructure everywhere. That’s how voluntary pledges become standardized environmental transparency.
Your Next Steps
-
Map suppliers to Tier 4 for your top categories. Start where volume or risk is highest (denim, leather, synthetics with complex dye/finish).
-
Baseline Scope 1–3 for fashion operations, then assign reduction targets per material and supplier cluster; align methods with California’s disclosure rules.
-
Clean up marketing language. Build an internal “claims library” that defines “recycled,” “low-impact,” “biobased,” etc., with sources and test methods – Washington will ask.
-
Digitize your product files. Create DPPs for core styles so supplier, certificate, and impact data are one click away for audits, retail partners, or regulators.
-
Pressure-test chemicals compliance. Cross-check priority chemical lists against current inputs and lab reports, especially for finishes and trims, in light of AB 405’s thresholds.
Statehouses are writing the new rules of engagement for U.S. fashion. The companies that treat this as an operations upgrade will move faster, market more credibly, and compete globally on verified performance.
World Collective’s ecosystem was built for this pivot. Our Digital Product Passports (DPPs) store verified supplier, certification, and impact data at product level; supplier mapping gives brands and manufacturers shared visibility; and Eco-impactor converts inputs into decision-grade metrics you can publish or submit. We’re not a watchdog, we’re the connective infrastructure that makes compliance achievable and commercially useful. When data flows, compliance becomes faster sampling, quicker buyer approvals, and fewer claims risks.
If you sell to those states or plan to in the next 12–18 months, we can stand up supplier mapping, DPPs, and product-level impact reporting on a deadline.
Get state ready now with our living Ecosystem, link here.
