This article is a contribution from Next Gen Assembly 2025 Member Elise Dauterive and opinions expressed do not represent the views of Global Fashion Agenda nor those of its Partners.

When I started my master’s thesis on California’s new textile Extended Producer Responsibility programme last spring under the guidance of my faculty adviser Dr Roland Geyer, I approached it as a promising development in American circular economy policy. SB 707, the Responsible Textile Recovery Act of 2024, requires producers to take responsibility for the textile waste Americans generate annually, most recently estimated at 17 million tonnes in 2018, with 85% ending up in landfills or incinerators.

Nine months into researching this emerging policy landscape through stakeholder interviews with organisations including the OECD, California Product Stewardship Council, CalRecycle, the American Apparel & Footwear Association, prospective Producer Responsibility Organisations, American Circular Textiles, Goodwill Inc., recyclers, and waste haulers, I’m learning that EPR is a valuable tool, but needs to evolve to answer a fundamental question: does it actually reduce environmental burden, or does it just manage waste more efficiently?

Beyond Collection Rates

The OECD’s 2024 report on garments EPR provides helpful context: figures suggest that textile production more than quadrupled from 24 million tonnes in 1975 to 108.3 million tonnes in 2020, with synthetic fibre production increasing nearly eight-fold.

France’s programme demonstrates both achievement and limitation. It reports impressive collection rates and sorting infrastructure with a 60% “re-use rate” for collected material, significantly outperforming the EU average of 8%. Yet, textiles placed on the French market reportedly grew 66% from 2020 to 2022. This reveals EPR’s current design constraint: it focuses on what happens after products enter the waste stream without addressing production volume.

The distinction between managing waste and reducing environmental burden is fundamental to whether EPR achieves its purpose. Fashion is a significant consumer of finite resources and contributes to global GHG emissions, driving deforestation, pollution, climate change, and ecosystem depletion that threaten soil health, biodiversity, water resources, and communities. Figures suggest that textile production accounts for between 1.78% and 4% of global greenhouse gas emissions. If recovered fibres enter the market but manufacturers continue producing the same volume from resource-intensive extraction, EPR adds processing steps without reducing environmental impact. As Dr. Geyer emphasises in his research on industrial ecology, recycling’s environmental benefit materialises only when secondary production actually reduces demand for primary manufacturing. Collection infrastructure improvements are valuable, but they don’t constitute environmental success unless recovery demonstrably reduces the extraction, water consumption, and emissions associated with virgin production.

The Data We’re Missing

One of the most significant challenges I’ve encountered is understanding where textiles actually go after end-of-use. As part of my thesis, my team systematically contacted thrift stores, shelters, donation kiosks, and collection points throughout our county. Most organisations either didn’t track quantities, didn’t have data available, or were unwilling to disclose what happens to unsold textiles.

This data gap reveals that current EPR schemes cannot answer the fundamental question of whether they’re achieving environmental benefit. California’s waste characterisation studies track what enters disposal systems but don’t track exports. The OECD data suggests that OECD countries exported 5 million tonnes of worn garments to non-OECD countries in 2021. Research indicates 40% of clothing at Ghana’s Kantamanto Market becomes landfill waste upon arrival. The difficulty of tracking this data is precisely why EPR schemes must prioritise obtaining it. Without material flow accounting showing whether recovered fibres reduce primary production, we cannot distinguish between genuine environmental progress and well-intentioned but insufficient waste management. The industry is said to generate 3.9 billion tonnes of CO2 equivalent annually. If EPR schemes cannot demonstrate they’re reducing this figure, they’re failing at their fundamental purpose regardless of collection rates.

Yes, tracking virgin versus recycled content sourcing decisions is difficult. However, the measurement difficulty doesn’t make the question less critical; it makes it more urgent. If we design EPR schemes around metrics we can easily measure (collection rates, sorting efficiency) rather than environmental outcomes, we’ll build expensive systems that perpetuate the problem.

Elements for Next-Generation EPR

Future EPR schemes need three interconnected design elements:

1. Measure environmental outcomes through production monitoring: EPR must track whether manufacturers decrease purchase of primary fibres as recovered materials become available. If virgin polyester production and cotton cultivation continue at current rates whilst recycling infrastructure expands, EPR is adding cost without environmental benefit.
2. Connect production authorisation to demonstrated recovery: Require producers to prove that a percentage of previous year’s production was recovered and reintegrated into supply chains before authorising equivalent production volume. This ensures recovery translates into avoided extraction and emissions, not just diverted waste streams.
3. Establish complete supply chain transparency: Digital material passports tracking garments from fibre production through end-of-life enable both sophisticated recovery operations and the data infrastructure to verify environmental outcomes. Include pre-consumer waste (10-30% of fabric lost during manufacturing) to create direct data links between production and waste generation. For exported textiles, producer responsibility should continue post-export.

California’s Opportunity

California’s SB 707 launches in 2028. The OECD concludes that “an EPR approach by itself will be insufficient to address all environmental impacts of garments”.

My research confirms this. Collection infrastructure improvements and sorting technology investments are necessary components of EPR, but they are not sufficient measures of success. California can design a programme that measures what matters: demonstrated reduction in resource-intensive primary production. This means tracking complete material flows including exports, verifying recovered material enters supply chains, and linking production authorisation to proven recovery that measurably reduces extraction, water consumption, and emissions.

The stakeholders I’ve interviewed are working hard to make textile circularity functional. They deserve EPR schemes designed to answer the right question for the long-term. Not “how efficiently can we collect and sort textile waste?” but “is recovery reducing the environmental burden of textile production?” Without mechanisms to answer the second question, EPR risks becoming an expensive system that makes us feel better about waste management whilst the environmental crisis continues unabated. California has the opportunity to design an EPR programme that prioritises environmental outcomes by investing in the data infrastructure required to measure them. Yes, tracking material flows and virgin production displacement is complex and resource intensive. But without this capability, we cannot verify whether EPR is achieving its environmental purpose.

Elise Dauterive is a graduate student at the Bren School of Environmental Science & Management, University of California, Santa Barbara, and a member of GFA’s Next Gen Assembly 2025 cohort.