This summer, US fashion brands face two separate but simultaneous compliance obligations. On July 1, 2026, California Senate Bill 707 (SB 707), the United States' first textile Extended Producer Responsibility (EPR) law – requires brands selling apparel in California to register with the state-approved Producer Responsibility Organisation (PRO). Six weeks later, on August 12, 2026, the EU Packaging and Packaging Waste Regulation (PPWR) enters full application, requiring any brand placing packaging on the European market to meet new EPR obligations.
These are not two versions of the same rule. SB 707 targets the textile product itself. PPWR targets the packaging it ships in. But if your brand sells apparel in California and ships to EU customers, both deadlines apply to you – and both require the same thing from your operations: verified supplier and material data that you probably don't have structured and ready.
That's the real compliance problem this summer. Not two regulations. One data gap, two deadlines. This article breaks down what each regulation requires, where your obligations overlap, and what to act on right now.
California Senate Bill 707 (SB 707), signed into law in September 2024, is the United States' first textile Extended Producer Responsibility (EPR) programme. EPR shifts the cost of end-of-life product management – collection, sorting, and recycling – from governments and consumers to the brands that place products on the market.
Under SB 707, any producer with more than $1 million in global annual turnover that sells new apparel or textile products in California must register with Landbell USA, the Producer Responsibility Organisation (PRO) designated by CalRecycle on February 27, 2026 – by July 1, 2026. Registration requires a flat annual fee of $1,000 for the 2026-2027 cycle and takes under ten minutes at register.landbellusa.com. Failure to register by the deadline is not a deferred filing: non-compliant producers face penalties of up to $10,000 per day, and up to $50,000 per day for knowing or intentional violations.
Note: As of the date of publication, the American Apparel and Footwear Association (AAFA) has filed a legal challenge to CalRecycle's selection of Landbell USA as the PRO. However, this litigation does not suspend existing statutory requirements. Producers remain legally obligated to register by July 1, 2026.
The data SB 707 requires brands to report includes fiber composition by product category and sales volume for products sold in California. For most brands, this data exists somewhere – but it typically sits across PLM systems, supplier spreadsheets, and material databases that were never designed to feed a regulatory reporting interface. That gap is the real operational challenge.
SB 707 applies regardless of where your brand is headquartered. California is the first US state to introduce textile EPR, but New York, Washington, and Massachusetts have textile EPR legislation in various stages of development, each tracking close behind.
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) is the EU's updated framework for packaging waste management, replacing the previous Packaging Directive with a directly applicable regulation that harmonises requirements across all EU member states. PPWR entered into force on February 11, 2025, with full application from August 12, 2026.
For fashion brands, PPWR covers the full range of packaging formats used in the industry: polybags, shoeboxes, tissue paper packaging, hang tags with plastic components, and e-commerce outer shipment packaging. Under PPWR, brands must participate in national EPR schemes for packaging in each EU member state where they place packaging on the market. These EPR contributions fund the collection, sorting, and recycling infrastructure for that packaging.
The core reporting requirement for August 2026 focuses on packaging material composition, recyclability, recycled content percentage, and quantities placed on the market by member state. It is worth noting that national EPR schemes in key markets such as Germany, France, and the Netherlands are already active – brands selling into those markets may already be obligated. August 12 is the date the harmonised PPWR framework applies simultaneously across all 27 EU member states. These requirements sit alongside broader PPWR design mandates – including recyclability thresholds and restrictions on unnecessary packaging – but the EPR registration and reporting obligation is the immediate compliance deadline.
Yes. PPWR applies to any brand that places packaging on the EU market, regardless of where the company is headquartered. A US brand shipping apparel to EU consumers – through direct-to-consumer e-commerce, a marketplace, or a wholesale partner – is placing packaging on the EU market and is in scope.
For non-EU brands, the practical compliance requirement is to appoint an authorised representative in each EU member state where they sell. That representative acts as the legal entity registered with the national EPR scheme, fulfilling reporting and financial contribution obligations on the brand's behalf. Brands selling into multiple EU markets need a representative structure that covers each of them.
The legal anchor under PPWR is whichever entity first places the packaging on the EU market. A US brand shipping directly into a German warehouse or third-party logistics facility for onward delivery to French consumers is in scope from August 12, 2026.
Both SB 707 and PPWR require brands to know, at a structured and verifiable level, what their products and packaging are made of. The specific data fields differ – SB 707 focuses on fiber composition and sales volume for the textile product itself, while PPWR focuses on packaging material composition and recycled content. But the underlying infrastructure requirement is the same: supplier data collection, verification, and structured regulatory reporting.
Here's where the efficiency opportunity sits. Brands already running supplier outreach for SB 707 fiber data are in the best position to extend that engagement to capture PPWR-relevant packaging material data at the same time. The marginal cost of adding a packaging data field to a supplier engagement that is already happening is close to zero. Running two separate supplier outreach programmes is not.
The shared foundation is a centralised, multi-regulatory data layer: one place where supplier and material data is collected, verified, and structured to satisfy whichever regulation requires it. That is the architecture that makes global EPR compliance manageable as the regulatory environment continues to expand.
Yes, and it is worth building for now, even though the formal brand compliance deadline is still years away. The revised EU Waste Framework Directive (WFD), which entered into force on October 16, 2025, introduces mandatory EPR for textiles across all EU member states. Member states have until June 2027 to transpose the directive into national law and until April 17, 2028 to establish functioning EPR schemes for textile and footwear products.
Several EU member states are already ahead of the 2028 deadline. France has operated its national textile EPR scheme through REFASHION since 2007. Other member states are developing their frameworks now, and the pace of implementation is expected to accelerate as the 2028 deadline approaches. When these schemes are established, any brand placing textile products on those markets -- including US brands -- will be required to register and contribute.
The data requirement for EU textile EPR will mirror what SB 707 already demands: fiber composition, material traceability, and sales volume by product category. Brands building their SB 707 compliance infrastructure now, and structuring it to be flexible rather than point-built for a single regulation, will have a meaningful head start on EU textile EPR registration by 2028.
Three actions matter most between now and August 12:
Yes. SB 707 applies to any producer with more than $1 million in global annual turnover that sells new apparel or textile products in California, regardless of where the company is headquartered. If your products are sold in California, registration with Landbell USA by July 1, 2026 is required. Non-compliance can result in penalties of up to $10,000 per day.
The American Apparel and Footwear Association (AAFA) filed a legal challenge in March 2026 to CalRecycle's selection of Landbell USA as the PRO for SB 707. A preliminary injunction hearing is scheduled for August 7, 2026. Importantly, the pending litigation does not suspend existing statutory requirements. Producers remain legally obligated to register with Landbell USA by July 1, 2026. Brands should monitor developments at americancirculartextiles.com/sb-707-implementation-tracker and consult legal counsel for guidance on their specific situation.
PPWR requires any brand placing packaging on the EU market, including US brands, to participate in national EPR schemes in each member state they sell into. Non-EU brands must appoint an authorised representative in each relevant member state. Full harmonised compliance applies from August 12, 2026, though several national schemes (Germany, France, Netherlands) are already active.
PPWR covers all packaging formats used in the fashion industry, including polybags, shoeboxes, tissue paper packaging, hang tags with plastic components, and e-commerce outer shipment packaging. If it enters the EU market with your product, it is in scope.
California SB 707 is an EPR scheme for the textile product itself – targeting fiber composition and end-of-life management of apparel. EU PPWR is an EPR scheme for the packaging the product arrives in. Both apply to US fashion brands selling in their respective markets, but they target different parts of the product.
No. EU PPWR covers packaging. EU textile EPR, introduced under the revised Waste Framework Directive (which entered into force October 16, 2025), covers the textile product itself and requires EU member states to establish national EPR schemes for textiles by April 17, 2028. Several member states, including France through its REFASHION scheme, are already operating textile EPR ahead of that deadline.
TrusTrace is the multi-regulatory supply chain and product compliance platform for global brands. Trusted by companies representing over $200 billion in combined retail sales, TrusTrace gives brands one data foundation to power every compliance requirement – California SB 707, EU PPWR, EU Textile EPR, EUDR, and beyond.
Contact TrusTrace to understand how your brand can build one supplier data programme that satisfies both your 2026 EPR deadlines and prepares you for what comes next.
Disclaimer: This content is for informational purposes only and does not constitute legal advice. Please consult legal professionals for guidance specific to your situation.