Two pieces of US apparel disclosure law matter for mid-to-large brands in 2026: California's Transparency in Supply Chains Act (SB-657), on the books since 2012, and New York's Fashion Sustainability and Social Accountability Act, which has moved through the legislature in multiple versions with new drafts each session.
For brands with a California presence (most national brands have one), SB-657 is already your law. For brands with global revenue over $100 million, NY's Fashion Act — in whatever form ultimately passes — should be on your compliance roadmap.
This is an operational walkthrough, not legal advice. Coordinate with counsel on the edge cases that matter to your business.
California SB-657 — Transparency in Supply Chains Act
Who it applies to: Any retail seller or manufacturer doing business in California with annual worldwide gross receipts over $100 million. The threshold looks at your global revenue, not California-only. If your apparel brand exceeds the threshold and sells in California (virtually any national brand does), you're in.
What it requires: A publicly accessible disclosure — prominently linked from the company's homepage — describing the extent to which the company engages in the following five areas:
1. Verification
The company's efforts to verify product supply chains to evaluate and address risks of human trafficking and slavery. Disclose whether verification is done by a third party.
2. Audits
Whether the company conducts audits of its suppliers to evaluate compliance with standards for human trafficking and slavery. Disclose whether audits are announced or unannounced, and whether third-party or internal.
3. Certification
Whether the company requires direct suppliers to certify that materials incorporated into the product comply with applicable laws regarding slavery and human trafficking in the countries where they do business.
4. Internal accountability
The company's internal accountability standards and procedures for employees or contractors who fail to meet standards regarding slavery and trafficking.
5. Training
Whether the company provides company employees and management with training on human trafficking and slavery, particularly with respect to mitigating risks within supply chains.
What has to be on the website: A "conspicuous and easily understood" link on the homepage, taking users to the disclosure. The disclosure itself should be plain-language and substantive — not legalese, not empty affirmations.
What a compliant disclosure looks like
Five paragraphs, one per topic, each of which should:
- Describe what you actually do (not aspirational language)
- Note any third-party involvement (independent auditor, certifier, training provider)
- Acknowledge limits honestly (e.g., "our verification covers tier-1 and tier-2 suppliers; tier-3+ visibility is limited")
A good disclosure is specific and honest. A bad one reads like marketing: "Company X is committed to the highest standards of ethical manufacturing worldwide." That language, on its own, does not describe efforts — it describes intentions — and NGOs and AGs reading these statements have noticed.
Where it lives
- A link from the homepage footer labeled "California Transparency in Supply Chains Act" (or similar) pointing to a dedicated page
- The dedicated page under a URL like /legal/sb657-disclosure or /responsibility/supply-chain
- Reviewed and updated annually (at minimum) — the statute doesn't require annual updates, but stale disclosures invite scrutiny
New York's Fashion Sustainability and Social Accountability Act
Status in 2026: The Act has been re-introduced in multiple versions since 2021. As of early 2026, it has not been signed into law in the form the early drafts proposed, but versions under active consideration include requirements that go well beyond SB-657:
Who it would apply to: Fashion retailers and manufacturers doing business in New York with annual worldwide gross revenue over $100 million (similar threshold to SB-657, similar capture of major apparel brands).
What it would require (based on the iterations discussed publicly; specifics may change in whichever version becomes law):
1. Supply-chain mapping. Public disclosure of at least 50% of the supply chain by volume or cost — covering farms, factories, shipping, waste streams, and more. This is materially more than SB-657 requires.
2. Social and environmental due-diligence reports. Annual reports describing the company's efforts to identify and mitigate negative impacts — aligned with OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector.
3. Science-based targets. Setting and publishing emissions-reduction targets aligned with the Science Based Targets initiative (SBTi), including Scope 1, 2, and 3 emissions.
4. Remediation plans. Where due diligence identifies harms (e.g., underpaid workers, chemical exposures), published plans to address them.
5. Enforcement mechanism. Civil penalties for non-compliance, enforced by the NY Attorney General, with the potential for private rights of action in some drafts.
Why it matters even if not yet law
Brands preparing for NY Fashion Act compliance are effectively preparing for the EU's Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Corporate Sustainability Reporting Directive (CSRD), both of which impose similar requirements on companies selling into Europe. The compliance infrastructure is shared: supply-chain mapping, due-diligence processes, emissions reporting.
A brand that waits for each jurisdiction to pass its version of the law, then scrambles, will be perpetually behind. A brand that builds the infrastructure once — mapping, due diligence, reporting — satisfies all of them with one effort.
Practical next steps
Whether or not any specific law applies to you today:
- Inventory your supply chain. You probably know your tier-1 factories. Do you know their spinners? Their ginners? Start with your top 10 SKUs.
- Codify your audit program. Even if it's "we audit our tier-1 suppliers annually via SMETA," write down what you do, formalize it, and keep the artifacts.
- Publish an SB-657 disclosure if you're at the threshold. It's required; it's public; it's easy to get wrong. Use a template from a credible legal source and tailor it to your actual practices.
- Track what's in scope. Subscribe to the NY State bill tracker, follow the industry briefs from Textile Exchange or the Sustainable Apparel Coalition, and adjust your infrastructure as laws land.
Frequently asked questions about apparel disclosure laws
Who actually has to comply with SB-657?
Any "retail seller or manufacturer" doing business in California with annual worldwide gross receipts exceeding $100 million. For apparel brands, this catches nearly every national retailer and any brand with wholesale distribution to major accounts. The threshold is corporate-wide revenue, not California-specific. Smaller brands are not directly covered but often adopt the same disclosures voluntarily because their retail partners require them.
What's the status of the NY Fashion Act in 2026?
The Fashion Sustainability & Social Accountability Act has been re-introduced in multiple legislative sessions with evolving thresholds. As of early 2026, versions under consideration apply to fashion retailers and manufacturers with more than $100 million in global revenue and require mapping at least 50% of the supply chain (by volume or cost), setting science-based targets for emissions, and disclosing due-diligence efforts on social and environmental risks. Check the NY State Senate bill tracker for the current status — the specifics of which version (if any) passes will shift the exact compliance list.
Does an SB-657 disclosure have to name names?
Not every tier. The statute requires disclosure of efforts in five areas (verification, audits, certification, internal accountability, training) but doesn't require you to name every supplier. Most disclosures published today use general language ("we audit our tier-1 suppliers quarterly via an independent third party") without listing specific factory names. You can name names if you want to, and some brands do for credibility — but the law doesn't mandate it.
What happens if we publish an inaccurate SB-657 disclosure?
The California Attorney General has exclusive enforcement authority and can seek injunctive relief. More practically, a misleading disclosure creates exposure to consumer-protection class actions, unfair-competition claims, and reputational damage when NGOs cross-reference your statement against leaked supplier lists. The sanction isn't usually a direct fine — it's being publicly embarrassed or sued for misstating your practices.
Related reading
- UFLPA Compliance for Apparel Buyers: A Non-Lawyer's Playbook — federal forced-labor law that pairs with state-level disclosure requirements.
- SA8000 vs Fair Trade vs BSCI: Which Social Audit Matters — audits that provide the "verification" and "audits" substance for an SB-657 disclosure.
- How to Vet a Manufacturer: A 12-Point Checklist — vetting is where traceability starts; disclosures are where it's reported.
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