First, the regulators came for tires, mattresses and batteries. More recently, Canada, Europe and seven U.S. states have taken aim at reducing packaging waste.
Now it’s time to start thinking about textiles like T-shirts and hoodies, which consistently rank among the most popular products in promo.
California is once again the vanguard for a state-level regulation that will affect businesses far and wide, this time with the Responsible Textile Recovery Act of 2024 (aka SB 707). This textile circularity measure was passed and signed into law last fall and is the first-ever extended producer responsibility measure in the United States that addresses end-of-life services for textiles.
- Legislatures in New York and Washington state have considered similar legislation, but nothing has passed either statehouse as of this writing.
- In 2022, Massachusetts enacted a ban on landfilling or incinerating textiles, requiring individuals and business to find reuse or recycling programs. However, the law does not include an EPR program requiring textile producers to establish or fund such programs.
Discarded clothing is the main source of textiles in municipal solid waste systems, according to the U.S. Environmental Protection Agency. The rapid rise of fast fashion in the past decade has exacerbated the burden on these facilities, making textile waste one of the fastest-growing categories of waste worldwide.
With the Responsible Textile Recovery Act, California aims to ensure that used textiles are collected and reused, repaired or recycled instead of going to a landfill. Like other EPR laws, the approach is to shift financial and operational accountability for these efforts away from taxpayers and municipalities and onto the companies that put apparel and other textile products on the market.
RELATED: EPR Laws Are Coming For Your Company’s Packaging Data
What Promo Firms Need To Know About SB 707
It’s important to understand whether and how your company is obligated under the law, as well as how the program will roll out.
- First, the state will select one of several entities currently applying to be selected by March 1, 2026, as the sole producer responsibility organization that will facilitate the program.
- A key registration deadline is coming up (July 1) just a few months after the PRO is chosen, but program fees and enforcement won’t begin for several years after that so that the PRO has time to conduct a needs assessment and work out program details.
Here are some frequently asked questions and answers for SB 707:
Who Is A Producer Under SB 707?
The law applies to entities that sell apparel and textile products in California, and “producer” is defined in a hierarchical way, according to who has a business presence in the state:
- The manufacturer.
- The product importer or exclusive licensee.
- The distributor/wholesaler or product distributor/retailer.
Secondhand sellers and businesses with less than $1 million in annual global sales are exempt.
What Products Are Included Under SB 707?
SB 707 covers a wide range of apparel and textile products. While clothing (including undergarments) is the primary target, the law also includes bags, fabric accessories (like scarves) and fabric footwear, as well as knitted and woven home furnishings and accessories (curtains, towels, etc.)
- The full list of covered products will be supplied by the PRO at a future date.
What Is The Timeline To Implement SB 707?
- September 2024: California’s Responsible Textile Recovery Act (SB 707) was signed into law by Gov. Gavin Newsom.
- January 1, 2026: Potential producer responsibility organizations must apply to CalRecycle.
- March 1, 2026: CalRecycle will select a single PRO.
- July 1, 2026: Producers must join the PRO.
- Mid-2026 to mid-2028: The PRO will conduct a needs assessment and rulemaking for the program.
- July 1, 2028: CalRecycle must adopt implementing regulations.
- July 1, 2030: Full program rollout and enforcement: All obligated producers must have an approved stewardship plan or face daily fines (up to $50,000), and CalRecycle will maintain a public list of compliant producers.
- July 2030 & beyond: Producers must report annually to CalRecycle.
The needs assessment, to be conducted over the next two years, will provide a comprehensive analysis of the textile recovery activities and infrastructure in California and identify any gaps. This information will help shape the program rules and implementation CalRecycle will adopt in 2028.
Who Is California’s PRO For Textiles?
Several organizations are preparing applications to be the state’s textiles PRO, including the Textile Renewal Alliance, a coalition created by a group of industry associations that includes the American Apparel & Footwear Association and National Retail Federation. TRA hosted a webinar explaining SB 707 requirements and timelines on December 10.
SB 707 was written broadly to provide flexibility to the PRO as it uses data from the needs assessment to draft program rules and clarify the scope of the law, said Marisa Adler, senior consultant at Resource Recycling Systems, which helped set up TRA, during the presentation.
“I want to underscore the importance of the needs assessment. It really is a critical step to collecting information about recovery systems that are available today, how they’re performing and what gaps need to be filled to meet the requirements of the law,” she added. “It’s a big project in a limited amount of time, but it’s going to really help inform the development of the program itself.”
The rulemaking will include outreach to stakeholders and opportunities for manufacturers, recyclers and others to weigh in.
“The law itself is not overly prescriptive. It’s more of a framework, and a lot of that is very intentional because it allows CalRecycle and the PRO the flexibility in determining how the statutory requirements will be met,” Adler said, “and that happens through the rulemaking process and the program plan development.”
Best Practices For SB 707 Compliance
Although full program implementation is still several years out, it’s critical that producers prepare now, says Ammi Borenstein, founder & CEO of Snaplinc Consulting and featured speaker in PPAI’s packaging EPR webinar.
“SB 707 compliance is going to be a heavy lift for every covered entity,” he adds. “With no current systems in place for end-of-life textile management, the upcoming requirements are daunting.”
- Several complex EPR laws, including SB 707, that are currently in the early stages will converge and become active in 2030. This will require extensive data submission from obligated companies to CalRecycle.
In a recent blog post on SB 707, Snaplinc recommends five best practices to launch your compliance efforts:
- Determine producer status.
- Engage with the PRO early.
- Start internal audits.
- Implement a reporting system.
- Engage stakeholders.
RELATED: WATCH: PPAI Hosts Packaging EPR Compliance Webinar
PPAI will continue to monitor the issue and provide updates, beginning in March 2026 with the announcement of the producer responsibility organization selected by CalRecycle and information to help producers register by the July deadline.
Please contact Rachel Zoch, PPAI’s public affairs manager, at rachelz@ppai.org if you have any questions about regulatory issues or government affairs.
