California SB 707: A New Era for Textile EPR

Background 

• California is implementing the first textile EPR program in the United States.

• Brands will be responsible for end-of-life textile management.

• Noncompliance fines range up to $50,000 per day.

The Responsible Textile Recovery Act of 2024 (California SB 707) was signed by Governor Gavin Newsom in September, 2024. It’s the first ever Extended Producer Responsibility (EPR) measure in the United States that addresses end-of-life services for textiles. With California textile waste amounting to 1.2 million tons in 2021, these materials represent one of the fastest-growing categories of waste in California and the world as a whole.  

As the fast fashion juggernaut has brought low-cost apparel to more people than ever, it has also led to unchecked and rapid disposal burdening waste management systems the world over. SB 707 shifts accountability from taxpayers to the companies that produce the apparel and its materials by incentivizing sustainable design, reuse, and recycling initiatives. 

What Companies Does SB 707 Apply To? 

California SB 707 applies to producers of apparel and textile products sold in California. This includes: 

• The entity that manufactures the products and owns or is the licensee of the brand or trademark. 

• The product importer or exclusive licensee. 

• If neither of the above are in the state, the distributer/wholesaler or product distributor/retailer.  

The exemptions for SB 707 are: 

• Secondhand sellers. 

• Businesses with less than $1 million in annual global turnover. 

What Materials Does SB 707 Cover? 

SB 707 covers apparel and textile products—primarily clothing and undergarments. However, other covered materials include: 

• Accessories like handbags, backpacks, and scarves 

• Footwear 

• Swimwear 

• Curtains and fabric window coverings 

• Knitted and woven home accessories 

This is not an exhaustive list of covered materials. The bill defines a “covered product” as any apparel, textile, or textile article that is unsuitable for reuse by a consumer in its current state or condition. The full list of covered products will be supplied by the Producer Responsibility Organization (PRO) at a future date. 

What Are the SB 707 Requirements? 

SB 707 requires that producers actively manage the end-of-life of textile products. The steps include: 

• Producers must form a PRO. 

• PRO must develop a statewide plan for collection, transportation, repair, sorting, laundering, recycling, and safely disposing of post-consumer textiles.  

• Plan must include free and convenient collection systems such as drop-off sites or mail-in options for consumers. 

• Producers must report annually to CalRecycle on progress. 

Key SB 707 Deadlines 

• January 1, 2026: Producers must form a PRO. 

• July 1, 2026: Producers must join the PRO. 

• July 1, 2028: CalRecycle must adopt implementing regulations. 

• July 1, 2030: Full program rollout and enforcement. 

Noncompliance Penalties for SB 707 

CalRecycle will maintain a public list of compliant producers. Noncompliance will come with significant financial consequences: 

• Civil penalties up to $10,000 per day for standard violations. 

• Up to $50,000 per day for intentional, knowing, or reckless violations. 

Noncompliant companies will face a significant burden to prove their violations are not intentional or that they were unaware of the violation occurring, making detailed recordkeeping and reporting a must. The fines will be deposited into the Textile Stewardship Recovery fund and will pay for enforcement and program costs. 

Challenges of Recycling Textiles

SB 707 will bring challenges textile companies have never faced before. Primary challenges include:

• Establishing and scaling collections and recycling infrastructure.

• Collaborating and coordinating the entire supply chain.

• Navigating complex compliance burdens.

• Driving consumer engagement and behavioral shifts.

• Acommodating the wide variety of textile materials recyclability.

These unknowns and the wide range of requirements under SB 707 poses a challenge hardly any companies are prepared for.

Best Practices for SB 707 Compliance 

Although five years remain until full program implementation at the time of writing, producers must be proactive in this monumental undertaking. Unlike other EPR programs such as those that cover packaging or consumer electronics, there is no existing infrastructure in place to fulfill the end-of-life program requirements for textiles and apparel.  

Covered producers must plan carefully and consider working with an SB 707 consultant to ensure obligations are met and establish a strategic timeline. This will help ensure compliance when program implementation arrives. Here are five best practices to launch your SB 707 compliance efforts. 

1. Determine Producer Status: Are you a manufacturer, brand, importer, distributor, or more than one of these? SB 707’s tiered definitions can be complicated and require different levels of responsibility.  

2. Engage With PRO Early: Producers must form a PRO by January 1, 2026, and joining the coalition establishing it is a great way to gain insight and influence over the stewardship rules. Either way, join and get involved with the PRO as soon as possible to stay informed. 

3. Start Internal Audits: You won’t be able to efficiently achieve compliance if you don’t already have clear insight into the lifecycle impact of your materials. Set up protocols for data collection and tracking early. An SB 707 consultant can help kickstart this process efficiently

4. Implement a Reporting System: Your annual updates and brand lists are expected to be accurate under penalty of perjury, so the sooner you set up a robust reporting system the better. 

5. Engage Stakeholders: Everyone from the C-suite to staff, suppliers, and consumers will be affected by SB 707 implementation. Prepare education and training materials to get everyone on board before the program goes into effect.  

Start Strong With Snaplinc 

SB 707 compliance is going to be a heavy lift for every covered entity. With no current systems in place for end-of-life textile management, the upcoming requirements are daunting. Snaplinc specializes in EPR and has guided clients in other industries through complicated data collection and reporting. Our SB 707 consultants are experts who are already well-positioned to take on the complexities and challenges of SB 707 so your teams don't have to scramble for compliance.  

Schedule an appointment with us today to learn more about how we can streamline your preparation for SB 707 compliance.