§ US US guide
US textile compliance checklist 2026.
The 10 items a US textile or fashion brand should work through in 2026: UFLPA tracing, California SB 707, FTC Green Guides, labeling, state chemical rules, and the EU obligations on export lines.
US textile compliance is no longer just labels and customs. Forced-labor tracing, state EPR, chemical restrictions, and claim substantiation each carry their own data demands, and the EU Digital Product Passport looms over any export line. The efficient play is one supplier data foundation feeding every regime. This checklist orders the work.
UFLPA supply-chain tracing
If you import textiles containing cotton or other at-risk inputs, CBP can detain shipments unless you can trace inputs deep enough to prove no Xinjiang forced-labor exposure. Maintain tier-3 and tier-4 origin documentation per style. Detentions run into weeks; the documentation pack has to exist before the shipment, not after the detention notice.
Target: Continuous
Textile Fiber Products Identification Act labeling
Federal law requires fibre content, country of origin, and manufacturer identification (RN number) on covered textile products. The FTC enforces. Verify every label template against the current rules, particularly for blends and trims.
Target: Every new style
FTC Green Guides on sustainability claims
Recycled content, biodegradable, and general environmental benefit claims must be substantiated and qualified. Certifications (GRS, RCS) are your evidence base. Review marketing claims against the Green Guides before campaigns, not after a demand letter.
Target: Every campaign
California SB 707: the registration deadline has passed
The Responsible Textile Recovery Act required covered producers to join the approved producer responsibility organization by 1 July 2026. That date is behind us. Producers with 1 million dollars or more in aggregate global turnover who place covered textiles on the California market are in scope, and the covered list is wide: adult and children's clothing, footwear, swimwear, uniforms, blankets, curtains, fabric window coverings, towels, linens and pillows. Reported penalties for failing to join run to 10,000 dollars per day, and up to 50,000 dollars per day for intentional or knowing violations. If you have not registered, that is the most urgent item on this page.
Target: Deadline passed 1 July 2026
California Prop 65 and state chemical rules
Textiles sold in California carrying listed chemicals above safe-harbor levels need warnings. PFAS bans on textiles are live or phasing in across California, New York, and other states. Get chemical declarations from your mills per fabric, not per assumption.
Target: Continuous
Confirm EU market exposure
Pull 12 months of sales by EU member state. Any EU sales bring ESPR into scope: Authorised Representative, producer registration per member state, and the Digital Product Passport from roughly 2028. See the ESPR guide for the full workload.
Target: Q1 2026
Tier-2 supplier data collection
Fibre composition, origin, dye chemistry, and certifications from your fabric mills. Takes 6-12 months and feeds UFLPA tracing, SB 707 data, Prop 65 diligence, and the EU DPP simultaneously. Start with the top 20% of suppliers by volume.
Target: Start Q1-Q2 2026
GTIN discipline via GS1 US
One GTIN per variant, allocated at design stage, stored in your ERP or PIM as the canonical identifier. Required for retail anyway; becomes the anchor of the GS1 Digital Link QR code if you sell into the EU or want scan-to-verify in the US.
Target: Q2 2026
Digital Product Passport pilot
Run a small pilot issuing passports for 5-10 SKUs. Even for US-only lines, retail buyers increasingly request DPP-shaped data contractually, and SB 707 will want the same material composition record. A pilot proves the data pipeline before any mandate forces it.
Target: Q3 2026
Document retention plan
UFLPA documentation, chemical declarations, claim substantiation, and (for EU lines) DPP data all carry multi-year retention expectations. Plan storage for 7-10 years as part of platform selection rather than as an afterthought.
Target: Q3 2026
Frequently asked
- Which of these applies to a US-only brand with no exports?
- Items 1 through 5 and 7 through 10. UFLPA applies to imports regardless of where you sell. Labeling, Green Guides, SB 707, and Prop 65 govern the US domestic market. Only item 6 and the EU-specific pieces drop away, and even then retail buyers increasingly request DPP-shaped data contractually.
- Is the Digital Product Passport a US legal requirement?
- Not federally, as of 2026. It is an EU requirement for products placed on the EU market from roughly 2028. In the US, California SB 707 points the same direction for material composition data, and large retail buyers are writing DPP-style data requirements into supplier contracts ahead of any law.
- How does UFLPA tracing overlap with DPP data collection?
- UFLPA establishes origin visibility down to raw fibre for cotton goods, deeper than the DPP fibre-origin field requires. Brands with mature UFLPA programs typically only need to add chemical declarations and durability data to reach DPP readiness, so the marginal cost of EU compliance is much lower than starting from zero.
- What does SB 707 actually require right now?
- Registration with the approved producer responsibility organization was due by 1 July 2026, so the first question is whether you are registered. Producers in scope are those with 1 million dollars or more in aggregate global turnover placing covered textiles on the California market, and the covered product list is broad. Reported penalties for failing to join reach 10,000 dollars per day, rising to 50,000 for intentional or knowing violations. Beyond registration, CalRecycle has been running stakeholder workshops through 2026 on definitions, online marketplaces, producer exemptions and end markets, with the needs assessment due from the PRO in March 2027 and the full program plan in July 2029. The practical work in the meantime is data readiness: knowing the material composition and recyclability profile of every covered product you place in California, because that is what the reporting will be built on.
- Can Filovera handle US-only compliance data?
- Yes. The passport data model carries the fields UFLPA tracing, SB 707 data readiness, and Prop 65 diligence rely on: per-component fibre composition, multi-tier origin, chemical declarations with certificates attached, and an audit trail of who submitted what. US-hosted region available; flat monthly pricing with unlimited passports.
Be ESPR-ready before the
deadline catches you.
Onboard your first SKUs, invite a supplier, publish your first scannable passport, all inside a 14-day Starter trial. When it ends you drop to the Free plan and keep your passports live. No credit card, no expiry.