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Update on California’s Fashion Environmental Accountability Act

On April 10, 2025, the California Assembly approved an amendment to Assembly Bill 405, also known as the Fashion Environmental Accountability Act of 2025. This marks a significant shift in California’s regulatory approach to chemical substances in the fashion industry. 

From Supplier Reporting to Product Compliance 

The original version of the bill required fashion sellers to collect and report annual data from their tier 2 suppliers. These suppliers, typically involved in dyeing, finishing, printing, and garment washing, were expected to provide information on water usage and concentrations of chemicals found in wastewater. The collected data was intended to be included in the seller’s annual Environmental Due Diligence Report. 

Following the recent amendment, this reporting requirement has been eliminated. Fashion sellers are now directly responsible for ensuring that their covered fashion products do not contain regulated chemicals in concentrations exceeding the limits established by the law. 

Regulated Substances and Permitted Limits 

The amended bill defines specific thresholds for the presence of certain chemical substances in finished fashion products. The permitted levels are as follows: 

  • Azo-amines and arylamine salts: not greater than 20 parts per million 
  • Bisphenols: 
    • Bisphenol A in textiles and leather: not greater than 10 parts per million 
    • Bisphenol B and Bisphenol F: not greater than 100 parts per million 
    • Total bisphenols: not greater than 200 parts per million 
  • Flame retardants: not greater than 10 parts per million 
  • Formaldehyde: not greater than 75 parts per million 
  • Phthalates: not greater than 500 parts per million 
  • Lead: not greater than 1 part per million 


Penalties for Non-Compliance
 

Any violation of these requirements may result in administrative or civil penalties. The maximum fine is $5,000 for a first violation and $10,000 for each subsequent violation. 

Legislative Progress and Outlook 

The amendment has passed the second reading in the California Assembly. If adopted into law, it will set an important regulatory precedent by imposing strict chemical safety standards on finished fashion products. These obligations are aligned with global initiatives such as the European REACH regulation but are tailored to ensure compliance at the product level for the United States market. 

 

Regulatory Reference 

Assembly Bill 405, Fashion Environmental Accountability Act (State of California, USA, 2025) 

 

Contact us to learn more about how we can support your compliance with AB 405 and other international chemical safety requirements. 

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