The

Traceability
Playbook
The

Traceability
Playbook
The TrusTrace Traceability Playbook is a complete guide to
achieving supply chain traceability in the fashion industry,
written in collaboration with Fashion Revolution and Fashion
for Good. Tapping the expertise of industry thought-leaders,
the playbook outlines the fundamentals of traceability,
highlights incoming legislation, provides a voice to suppliers,
and shines a light on traceability tech innovations reshaping
the industry. In the Three Levels of Traceability, discover step-
by-step instructions for achieving traceability in your
business, no matter where you are in your sustainability
journey. The Playbook epitomizes the TrusTrace mission to

accelerate sustainable transformation of the fashion industry.

contributors

Author contributors

Megan Doyle Liv Simpliciano James Crowley

Sustainable Fashion Journalist Fashion Revolution Fashion for Good
Megan is a sustainable fashion journalist and At Fashion Revolution, Liv is the policy & research As an innovation analyst at Fashion for Good’s
content editor at TrusTrace. With bylines in manager and is responsible for managing the delivery of Innovation Platform, James focuses on transparency
publications like the Business of Fashion, Luxury the Fashion Transparency Index and other key projects and traceability initiatives, innovation, and
Society, Fashionista, Refinery29, EcoCult and which drive industry transformation and increased implementation for brands and associated partners.
others, Megan covers everything from fashion tech accountability. She also leads strategic partnerships With an academic background in supply chain
to garment workers' rights, supply chain traceability with the investor and technology communities and traceability and sustainability, he completed his masters
and consumer psychology, as well as consulting academia among others. Early in her career, Liv worked in International Development at the University of
sustainable fashion businesses on how to with one of the world’s leading organizations to Amsterdam. Subsequently, he worked for Tony’s
communicate accurately and authentically. She also illuminate and remedy labour violations in supply chains, Chocolonely’s impact team, at PVH Corp. as a
has a monthly newsletter, the Titian Thread, which helping corporations, brands and governments to sustainability coordinator, and consulting on ESG and
rounds up notable news, content, and tools focused understand the risks of forced labour and human traceability implementation for impact-driven cocoa
on sustainability and ethics in the fashion industry.
trafficking across their supply chains. projects in Ghana, before joining Fashion for Good.

Advisors I nt e rvi ewee s

Baptiste Carriere-Pradal Ina Budde Maeve Galvin Akhil Sivanandan

Policy Hub circular.fashion Fashion Revolution Green Story

Madhava Venkatesh Paul Foulkes-Arellano Rogier van Mazijk Nicole Rawling

CTO & co-founder at TrusTrace Circuthon Fashion for Good Material Innovation Initiative

Ma nag in g E ditor

Marianne Uddman Amina Razvi Baptiste Carriere-Pradal Anja Sadock

Head of sustainability & innovation Sustainable Apparel Coalition Policy Hub Head of marketing at TrusTrace
at TrusTrace
contributors

About TrusTrace
TrusTrace was founded in 2016, with the vision to Fjällraven and Filippa K. The platform supports
fundamentally change the way fashion is produced and brands with risk management, compliance, product
consumed, after witnessing the detrimental effects of claims, footprint calculations, and the ability to
pollution of the local rivers, soil and air coming from confidently and easily share data about product
unregulated dying factories and textile manufacturers in origin and impact. It is built on AI, blockchain and
their local community in Coimbatore, India. BOTS, and through its open architecture it is able
TrusTrace offers a market-leading platform for supply to integrate seamlessly with retailer-, manufacturer-
chain transparency and traceability within fashion and retail, and supplier systems, as well as those of 3rd
to help brands accelerate sustainable transformation and parties such as certification agencies, lifecycle
progress towards science-based targets. As a leader in this datasets and other sustainability solution providers.
nascent space, TrusTrace is already fuelling global-scale TrusTrace is headquartered in Stockholm, Sweden,
traceability programs at brands such as adidas, Decathlon,
with offices in India, France and the US.

About Fashion Revolution

Fashion Revolution is a global movement campaigning
and consumption, incentivising fashion brands and
for a fashion industry that conserves and restores the retailers to improve their practices and advocating for
environment and values people over growth and profit. policy which holds the industry accountable for its
The organisation works in over 90 countries worldwide, impact. Projects include Fashion Revolution Week,

with both an innovative and international approach to a public campaign effort to increase awareness and
research, education and advocacy. inspire action, the Fashion Transparency Index, a report
Fashion Revolution was founded in 2014 by Carry analysing the social and environmental public disclosure
Somers and Orsola de Castro with the aim to increase of 250 of the world’s largest fashion brands, and the
transparency in the fashion industry and stand in solidarity Good Clothes Fair Pay campaign, a European Citizens’
with the people who make our clothes. Since then, it has Initiative for living wage due diligence legislation.
grown to be the world’s largest fashion activism movement, Fashion Revolution believes that systemic change is
mobilising citizens, brands and policymakers to make possible and that fashion can be a force for good, which is
positive change.
showcased through the Fashion Open Studio programme,
The key pillars of change which Fashion Revolution an initiative supporting the world’s most innovative
pushes for include shifting the culture of fashion production designers within a regenerative fashion system.

About Fashion for Good

Fashion for Good is the global platform for innovation. inform and empower people from across the world

At its core is the Global and Asia Innovation and creates open-source resources to action change.
Programme that supports disruptive innovators on Fashion for Good’s programmes are supported by
their journey to scale, providing hands-on project founding partner Laudes Foundation, co-founder William
management, access to funding and expertise, and McDonough and corporate partners adidas, C&A,
collaborations with brands and manufacturers to CHANEL, BESTSELLER, Kering, Levi Strauss & Co.,
accelerate supply chain implementation. Otto Group, PVH Corp., Stella McCartney, Target and
To activate individuals and industry alike, Fashion Zalando, and affiliate and regional partners Arvind, Birla
for Good houses the world’s first interactive museum Cellulose, Norrøna, Pangaia, Reformation, Teijin Frontier,
dedicated to sustainable fashion and innovation to Vivobarefoot, Welspun and W. L. Gore & Associates.

Special thanks to…

Denis Tarabanov Jocelyn Chan Josie Kao Linnéa Teljas Puranen Lisa Lerouge
Graphic design Global marketing communications Fact-checking Art direction & illustrations Sustainability analysis

Case Studies
Contents

7 Introduction
9 Defining Traceability and Transparency
10 The Business Case for Traceability and Transparency
by Fashion Revolution
11 The Traceability Ecosystem
13 Traceability Trends
2015 – Now
2030 Goals
EU Taxonom
Green Bonds & ESG Commitment
The COVID-19 Pandemi
Overproduction

Now – 2027
Complianc
Buy Less, Buy Bette
Waste Reduction

16 Business Models of the Future

Ren
Case Study: Nuul
Resal
Case Study: Reflaun
Recycl
Case Study: I:CO

19 Scaling Traceability
Case Study: adidas
Case Study: Gucci

21 Standardizing & Decentralizing Data

24 Materials, Innovation & Collaboration
24 Defining Sustainability by Fashion Revolution
26 Textile Trends
Next-Gen Material
Plastic-free Fashio
Regenerative Agriculture and Biodiversity

28 Material Glossary
29 Certification Challenges
30 Recyclable vs Recycled
Case Study: Global Fashion Agenda

32 Material Misconceptions
33 Traceability Innovation by Fashion for Good
Supply Chain Traceability Platform
Circularity Platform
Tracer Technologies

36 Supplier Investment and Collaboration

Sustainable Financin
Technologies to Improve Production
Contents

37 The Supplier Perspective

What are Suppliers Asking for
Case Study: Shimmy

40 The Business Drivers of Traceability

41 Laws and Regulations
The EU Green Dea
The Uyghur Forced Labor Prevention Ac
New York State Fashion Sustainability and Social Accountability Ac
The FABRIC Ac
The Laws and Regulations Timeline

47 Transparency and Communication

Greenwashin
Fashion Revolution’s Tips to Comply with Greenwashing Law
Information Dumpin
Communicating Product Specific Impact Data

49 Sustainability Beyond the Corporate Level

External Pressur
Internal Driv
Calculating Business Emissions

50 A Call for Collaboration

52 The Three Levels of Traceability

53 Manual vs Digital Traceability

55 Level One: Supplier Mapping

The Basics of Supplier Mappin
Why is it Necessary
How Do you Achieve it
Challenges and Limitations

56 Level Two: Product Traceability

The Basics of Product Traceabilit
Why is it Necessary
Product backward Traceability
How Do you Achieve it
Challenges and Limitations

58 Level Three: Material Traceability

The Basics of Material Traceability
Why is it Necessary
Fiber forward Traceabilit
Chain of Custody Models
How Do you Achieve Material Traceability
Challenges and Limitations

61 What’s Next?
62 Glossary of Traceability Terms
Introduction
introduction 7

If you’re a fashion industry professional,

by now you’ve undoubtedly heard of traceability.

Whether you’re well on your way to achieving
traceability within your business, or you’re just
starting the discovery phase, it’s never been
more important to keep on top of this ever-
evolving, business-critical topic.
The fashion industry produces somewhere chain scandals, such as the discovery that
between 80-150 billion garments every year
Uyghur forced labor was linked to cotton
and in 2015, its carbon emissions accounted for coming out of China, global leaders have begun
roughly 2% of a global carbon budget created to put in place punitive measures in the hopes
by the International Energy Agency to keep of avoiding future human rights violations.
global warming below 2°C degrees. Holding The fragility and complexity of our global
together this trillion-dollar industry is a supply chains has never been more apparent
complicated network of actors forming an than in the last few years, as the COVID-19
intricate web that spans the globe. pandemic continues to put immense pressure
While the statistics are alarming, the fact of on the flow of goods around the world. For
the matter is that these are only estimations. consumer goods like fashion, a product journey
The lack of accurate data caused by low-quality can involve raw material producers, processors,
information means that the industry has no true assemblers, certifying bodies, logistics providers
understanding of its environmental or social and retail outlets before reaching the end
impact. With huge data discrepancies, how can consumer. With potentially dozens of suppliers
we tackle these issues effectively?
per product, it's incredibly easy for information
Implementing traceability solutions to gain to slip through the cracks or be tampered with.

greater transparency over your supply chains Traceability isn’t just about mapping out your
can be a daunting task. Achieving traceability is supply chain – it’s a crucial part of managing
a resource-intensive aspiration for most fashion product certifications and relevant product
companies – currently, the majority have not labeling, calculating a product’s carbon
tracked their supply chains beyond tier one. footprint, and accurately communicating a
But incoming regulations, as well as increasing product’s story with your customer too. It’s
pressure from concerned consumers, is set also necessary for the discovery of social and
to put traceability at the top of every brand’s environmental issues as well as the remediation
agenda. At TrusTrace, we’ve experienced a of impacted stakeholders. In short, traceability
350% YoY increase of brand interest in our must be at the heart of any sustainability
traceability solutions, proving that traceability initiative.

is no longer optional, it’s a must-have.

If the industry is a web, TrusTrace is the
Whether you’re ready or not, regulations will spider connecting the threads. Since 2016,
change the game for fashion’s supply chains, it’s been our mission to shine a light on supply
reshaping the way business is done for the chains by building scalable data-driven tech
better. Following a number of high profile supply
solutions. We estimate that 95% of supply chain
introduction 8

information is currently being recorded As a leader in traceability, it's our

on outdated, inefficient analogue responsibility to illuminate the path so

systems, distributed across emails, that others can start their journey to
Excel spreadsheets and paper records. transparency, for the benefit of the entire
It’s no wonder that many fashion fashion industry and all its stakeholders.
businesses have difficulty tracking down Cross-industry collaboration is
the source of the cotton in their shirts fundamental to achieving this. We’ve
or the factory that made their buttons. collaborated with leading authorities
from the fashion industry, including
advocacy organization Fashion Revolution
At TrusTrace, we believe that and innovation accelerator Fashion For
brands shouldn’t need to be 
 Good to create a comprehensive playbook
perfect in order to be transparent. containing the insights you need to gain
Very few businesses have achieved traceability in your business.
transparency of their supply chains, Consider this playbook as a go-to manual
a task that is infinitely more for understanding the basics of achieving
complicated for larger businesses. supply chain traceability, from the key players
Our role is not to judge, but to guide operating within the vast supply chain
and support our partners through network, to the digital trends and innovative
their traceability journey. materials driving traceability forward. Our
ambition is to leave you with a solid
understanding of the business case for
Shameek Ghosh traceability, plus a step-by-step roadmap to
TrusTrace
achieve it. No matter where you are in your
traceability journey, we aim to help you get
further and achieve your goals faster.
Shameek Ghosh, CEO of TrusTrace
Defining Traceability & Transparency 9

Defining Traceability & Transparency

Traceability. In order to understand Transparency. Often thought of as
the ins and outs of traceability, we interchangeable words, traceability
need to define it. Traceability and transparency go hand in hand,
describes the process of tracing the but they have key differences.
origins, movement, and evolution of In comparison to traceability, which is more
products and materials. It sounds focused on internal tracking, transparency is
simple enough, but in reality, about the communication of information to
customers. Compared to the dynamic, real-time
traceability is incredibly complicated data that is linked to materials and products as
to achieve, especially for large brands they move through the supply chain, this
with thousands of products and information changes less frequently and can be
less complex. Transparency helps to hold brands
suppliers along the value chain, accountable to their commitments through
spread across multiple continents. increased public awareness and scrutiny, which
is a crucial component of creating a more
The information captured through traceability
equitable industry for all stakeholders.
can be granular – down to the specific
components and individual batches of a
product. Establishing traceability requires a Transparency relates directly to
sophisticated system to record data as a relevant information [being] made
product moves along the supply chain.







available to all elements of the value
chain in a standardized way, which
Traceability is the ability to trace allows common understanding,
the history, application or location accessibility, clarity and
of an entity by means of recorded comparison.
identifications. European Commission, 2017
ISO standard 9000:2015
Fashion Revolution has been publishing

Traceability is necessary to prove environmental

the Fashion Transparency Index (FTI) since
and social claims about a product so that
2017, ranking 250 of the world’s biggest
brands can avoid greenwashing, adhere to
brands in five key areas, including supply
certification criteria, and abide by regulations.
chain traceability. While there’s still work to
With increased visibility over their suppliers,
do, the industry has come a long way in

brands can more easily monitor for and uncover

this arena, reported the FTI in 2021.
social and environmental issues.

In the last few years, scandals have plagued

the industry – whether that is the production of
materials like leather and cotton contributing to
the deforestation of the Amazon or wage theft
perpetrated against garment workers. Alongside
this, recent supply chain crises caused by the
pandemic revealed the inflexibility of global
supply chains. The business case for traceability
has never been stronger.
The Business Case for Traceability & Transparency by Fashion Revolution
10

The Business Case for

Traceability & Transparency
B y F ashion Revolution

Major brands and retailers previously Growing interest in transparency can be partly
kept their supplier networks hidden, attributed to increasing consumer expectations
that brands and retailers are transparent about
which they viewed as their secret where, how and under what conditions
formula for deriving value and products are made. In 2020, Fashion
therefore something that had to be Revolution surveyed 5,000 European
consumers aged 16-75 and found that 74%
protected as a competitive advantage. believe fashion brands should publish which
However, in what was once considered a
factories are used to manufacture their
pipe dream for sustainability advocates,
products. 73% said fashion brands should
many brands and retailers have now become publish the suppliers further down the chain
more transparent by mapping and disclosing 
 where materials are sourced; the latter of which
their suppliers with the understanding that it has the least visibility at present and is the
won’t harm their competitive advantage,
source of most labor and environmental issues.
but rather can help them to: A 2018 study from Futerra and The
Consumer Goods Forum found that 94% of
More easily track unauthorised consumers are likely to be loyal to a brand that
subcontracting offers complete transparency. However, a 2021
study on sustainability and consumer behavior
Receive timely & credible information by Deloitte found that 46% of consumers are
from worker representatives which can looking for more clarity on the origin and
help mitigate labour & human rights risks sourcing of products, suggesting that brands
are still not disclosing enough information
Enhance brand trustworthiness and about their social and environmental impacts.
reputation among consumers and Despite this curiosity, the 2021 FTI found
investors that the average score across 250 of the
world’s largest brands and retailers was
Comply with an increasing number of just 23% — suggesting that progress on
social and environmental regulationss transparent disclosure of social and
environmental data is still too slow. The Deloitte
Validate data, such as facility name and survey, which queried 2,000 UK adults aged
location, to ensure greater accuracy of 18+, found that just 28% of consumers have
supplier information stopped buying certain products due to ethical
and environmental concerns. This figure could
Enable collaboration with other be higher, but among respondents, one of the
companies sourcing in the same
main barriers to making better choices is a lack
facilities
of access to information. If armed with
Identify bottlenecks and inefficient
knowledge, they would be better equipped
processes throughout the supply chain in to scrutinize brands’ practices.

order to improve workflows and save Fashion Revolution was inspired to

money create the FTI with the understanding that
transparency is a necessary — albeit not
Provide competitive advantage resulting radical — precursor to a fairer, cleaner and
in increased market share more accountable fashion industry.

The Traceability Ecosystem 11

The Traceability Ecosystem

In 2019, the fashion industry Suppliers
generated over $2 trillion in Suppliers are the cogs that keep the fashion
revenue. Making all this happen 
 machine running. A supplier is any company
is a hierarchy of actors. At one that produces or assembles a component of
a product, including the fabrics, finishings,
end are the leading fashion
threads, packaging, and garment tags. Major
brands that dictate the trends and fashion brands can have thousands of
establish business norms, while suppliers working within their supply chain.
at the bottom are the people who While an estimated majority of brands
make our clothes, and the groups publish their direct suppliers — the factories
that sew and finish their garments — the tiers
fighting to fix the human rights up the supply chain have a higher prevalence
violations and environmental of subcontracting and therefore a higher
harm that fashion leaves in its further likelihood of labor and human rights
wake. We’ve highlighted a
violations, according to a 2013 study
conducted by Sedex.
few of the leading actors in

each segment. NGOs

In the last decade, a number of non-
governmental organizations have been
Brands formed to advocate for different causes,

From luxury to the high street, the fashion from the plight of garment workers to the
industry is dominated by conglomerates. 
 environment. Among the leading global
In fact, just 10 groups, including Richemont, NGOs are Fashion Revolution, Remake,
PVH, LVMH, Kering, Boohoo Group, GAP Clean Clothes Campaign, Textile

inc, Inditex, Fast Retailing, H&M, and VF Exchange, and The OR Foundation.

Corp, own more than 100 of the biggest NGOs are critical in raising awareness 

of key issues in the fashion industry.
fashion brands in the world. Brands hold 

the most power in the fashion supply chain. 

Not only do they dictate trends, pricing, and Multi-stakeholder Initiatives
payment terms, but it’s common practice 
 Known as MSIs, these initiatives bring

for them to change suppliers frequently in together stakeholders from across the fashion
search of the most competitive prices, ecosystem to create industry-wide dialogue
and agree on solutions to common problems.
creating a lack of security for suppliers. Often, MSIs are financed by fashion brands but
Brands have the responsibility to
are independently governed. Leading MSIs
implement positive change within their include Better Work, Sustainable Apparel
supply chain and to influence the rest 
 Coalition, Fair Wear Foundation, Ethical Trading
of the industry to follow suit. Initiative, and the Fair Labor Association.
The Traceability Ecosystem 12

Certifying Bodies The efficacy of auditing bodies has come

under intense scrutiny in recent years, with
Increasingly, consumers look for third-party the Clean Clothes Campaigns’ 2019 Figleaf
certifications to guide their fashion purchasing for Fashion report alleging that they operate
decisions. Most certifying bodies specialize in in the interest of protecting brand reputation
one material category or social cause, doing rather than the safety of garment workers
everything from performing audits, lobbying and the environment. Most recently, a New
governments, campaigning, and educating York Times investigation exposed the
around this issue. Leaders in the certification fraudulent certification systems within the
space include B Lab, Bluesign, Global Organic organic cotton market. Working with auditing
Textile Standard (GOTS), Leather Working bodies doesn’t in itself prevent social and
Group, Ecocert, Canopy, Textile Exchange, environmental issues from arising. Brands
the Forest Stewardship Council (FSC) and the must respond to auditing results by
Better Cotton Initiative (BCI). It’s estimated implementing recommendations that work

that there are around 30 different voluntary in the interest of impacted stakeholders.
sustainability standards used by the industry.

Audit Bodies Traceability Tech Companies

Audit bodies are independent third-party TrusTrace isn’t alone in the ambition to

groups that perform on-the-ground revolutionize fashion supply chains through

assessments of facilities like farms and technology, and we believe in the power of

factories to ensure that they’re operating

collaboration, not competition. SupplyShift,
in compliance with certifications. Social TextileGenesis, Sourcemap and Reverse
Accountability International, Hohenstein Resources are among the tech platforms

Institute, Worldwide Responsible Accredited that TrusTrace works alongside to supply

Production (WRAP), and World Fair Trade the industry with data-driven solutions

Organization are notable auditing bodies.

to system-wide supply chain problems.
Traceability Trends 13

Traceability Trends
Over the last five years, 
 Despite the growing urgency of the climate crisis, 

a 2022 report from the Intergovernmental Panel
the fashion industry has faced a on Climate Change (IPCC) revealed that
heightened level of scrutiny from “according to current commitments, global
emissions are set to increase almost 14% over
concerned consumers, charitable the current decade.” Current pledges to lower
organizations, workers' rights emissions fail to take bold enough steps, creating 

groups, governments, and fashion a widening gap between the commitments and
the outcome. To achieve net-zero emissions by
industry professionals. 2050, McKinsey estimates that the annual
investment needed is $9.2 trillion a year.
Fueled by growing awareness of 

the climate crisis and the ongoing EU Taxonomy
repercussions of the COVID-19 pandemic, Introduced in 2020, the EU Taxonomy is a
fashion’s role in creating textile waste classification system for sustainable activities,
through overproduction, being complicit 
 with the goal to “redirect money towards
in the use of forced labor, and investing in sustainable projects” by fostering investment 

environmentally damaging farming and in areas that align with the Paris Agreement.
manufacturing processes has laid bare the The Taxonomy has established six
environmental objectives which “should create
broken system that the industry is built on.
security for investors, protect private investors
The next five years will be a crucial period from greenwashing, help companies to become
for the industry to pivot towards genuinely more climate-friendly, mitigate market
sustainable business practices. We’ve fragmentation and help shift investments 

identified the key trends that have informed where they are most needed.”

fashion in the last decade, as well as the

trends that will inform fashion’s sustainability Green Bonds and

strategies in the coming years.

ESG Commitments
2015 – Now The market for green bonds has boomed 

in the last two years, as investor appetite for
The 2030 Sustainable Environmental, Social and Governance (ESG)
funds continues to grow. Increasingly, investors
Development Goals
are interested in financing specific sustainability
In 2015, the United Nations identified 17 goals of companies, which could include 

Sustainable Development Goals and 169 reducing their carbon footprint by transitioning 

associated targets that provided a “supremely to renewable energy sources, or investing in
ambitious and transformational vision” for the certified sustainable materials. The market for
next 15 years. These goals have formed the green bonds grew by 49% between 2016 and
groundwork for sustainability strategies for 2021, according to Climate Bonds, and is
businesses that are committed to working within expected to reach $1 trillion by 2023.
the scope of Science-Based Targets, but these In 2020, Chanel became one of the first luxury
businesses are a dedicated few. There is a long fashion groups to issue Sustainability-Linked
way to go before the fashion industry achieves Bonds worth €600 million to support the brand’s
wide-scale, meaningful impact, but the SDGs Science-Based Targets approved carbon
provide a holistic framework for transformation. emission reduction goals.
Traceability Trends 14

The Covid-19 Pandemic

One of the biggest global events 

of the last decade, the pandemic
disrupted and exposed the flaws of 

the fashion ecosystem like nothing
before. Seemingly overnight, brands
with production hubs spread across the
world from Turkey to China were unable
to transport their products. With stores
closed, key revenue streams dried up
overnight, causing brands to cancel
orders (many that had already been
produced) with suppliers.
The fashion industry employs millions of
garment workers, many of whom were already
experiencing precarious employment and living
situations prior to the pandemic. The Clean but Euromonitor estimates that in 2016, U.S.
Clothes Campaign estimates that garment consumers bought 17 billion items of clothing,
workers lost $11.85 billion in unpaid wages trailing only behind China, where 40 billion units

from March 2020 through to March 2021. of clothing were purchased.

According to Fashion Revolution's research, In Fashion Revolution’s Transparency Index FTI

97% of brands did not publish the percentage 2021, only 14% of 250 brands disclosed the
of workers who lost their jobs due to the amount of clothing they produced each year.
pandemic, which paints an incomplete socio- The lack of transparency over the scale of
economic picture of the pandemic's impact overconsumption means that estimates could
on workers — amidst a climate where some possibly be much higher.
brands had record-breaking profits. When it’s no longer wanted, most of this
The pandemic has been a catalyst clothing ends up incinerated or in landfills,
for the acceleration of online shopping, (in the UK this amounted to 300,000 tonnes of
and the casualization of fashion. According clothing in household residual waste in 2015) or in
to McKinsey, e-commerce spending was up the global second-hand fashion market. The vast
30% from the beginning of March to mid- majority of clothing that is donated in Europe
April 2020, and unsurprisingly, British high ends up in Africa. At the Kantamanto market in
street stalwart John Lewis reported a Accra, Ghana, 15 million items of second-hand
1303% rise in sales of leggings and clothing are delivered each week, and 40% ends
loungewear in 2020.
up as waste, according to the OR Foundation.
People working in the second-hand clothing
trade in Kantamanto purchase bundles of
Overproduction clothing without any visibility into the quality
One of the most pressing issues facing 
 of the garments, meaning they often work at
the industry is the sheer volume of clothing an operational loss if the clothing they buy to
produced every year. Fashion continues to resell is unsellable. Transporting these bundles
operate in a linear model of producing, using is literally back-breaking work that young women
and disposing of apparel. Numbers vary on and girls undertake which often leaves them either
how much clothing is produced each year, seriously injured or with long-term health impacts.
Traceability Trends 15

Now – 2027
Compliance
For years, environmental and social impact
reporting has been done on a voluntary basis, 

but as the industry becomes increasingly regulated,
compliance is now business-critical. “We know that
reputation-sensitive brands are following policy
developments closely and preparing themselves for
compliance,” says Maeve Galvin, global policy &
campaigns director at Fashion Revolution.
“Certainly, the recommendations from multi-
stakeholder initiatives, policymakers and civil
society is for them to start preparing now.”
Failure to adhere to laws could result in financial
penalties as well as goods stuck at borders. prosperity. In fashion, all sustainability

It pays to not only comply but to go above and initiatives should be implemented in
beyond the current and incoming regulatory conjunction with an overall decrease in
requirements to avoid playing catch up as production, in order to make a significant
these evolve in the next few years.
reduction in GHG emissions.

Buy Less, Buy Better Waste Reduction

Dame Vivienne Westwood famously said: 
 According to WRAP, 4% of global waste 

“Buy less, choose well, make it last.” 
 comes from the fashion industry. In the US,
A movement away from cheap, disposable textile waste is outpacing the growth of every
fashion and a constant trend cycle is known as other type of waste, growing 78% by weight
Forever Fashion. In the coming years, experts between 2000 and 2017 — that’s an increase of
predict that consumers will invest in higher 54% per person. Circularity is a huge challenge
value, higher quality staple wardrobe pieces that for the fashion industry to build into the design
can be repaired and altered to extend their life. of clothing. It requires a total reimagining of the
Currently, consumer values and behavior manufacturing process so that clothing can
don’t line up. This is known as the attitude- easily be recycled and reused.
behavior gap — an issue that Zalando, and Zero-waste design is on the rise, aiming to
mitigate waste that occurs in the design and
others, have surveyed consumers about.
manufacturing process through sampling and
Zalando found that, while 60% of respondents pattern cutting. Brands are increasingly using
said that transparency was important to them,
deadstock and end of roll fabrics, repurposing
only 20% actively search for information about
scraps and swatches, swapping to recycled
brands while purchasing products. Closing this fibers, and designing patterns that can be cut
gap will be a challenge for the industry in the with minimal fabric wastage. In Europe, the
coming years. There is a growing interest in the New Cotton Project is a collaboration between
economic model of Degrowth, which is centred 12 fashion businesses like H&M, Fashion For
around lowering consumption and production Good, adidas, and others, to turn textile waste
and pivoting away from GDP growth as the into a new man-made cellulosic fiber that
primary indicator of a nation’s wellbeing and mimics the look and feel of cotton.
Business Models of the Future 16

Business Models of the Future

Rent
Companies like Uber and Airbnb have opened doors new, McKinsey estimates through interviews with rental
for the sharing economy. In fashion, this can be seen model executives that the lifespan of a product can be
through the rise of rental, which is expected to reach extended by 1.8 times. Seeing the growing
a market value of $7.45 billion by 2026. The rental opportunities in the rental space, fashion brands are
boom is led in the U.S. by Rent the Runway, as well keen to get in on the action. American label Vince
as smaller players like Le Tote and StyleLend. In the launched Vince Unfold in 2018, while Banana Republic,
UK, platforms include HURR, Rotaro, ByRotation, and a GAP Inc. brand, launched Banana Republic Style
Hirestreet. By renting a garment instead of buying Passport in 2019.

Case Study: Nuuly

Nuuly, with its platforms Nuuly Rent and Nuuly Thrift, is a member
of the URBN brand family, which also includes Urban Outfitters,
Anthropologie, Free People (brands included in the Fashion
Transparency Index) as well as BHLDN and Terrain.
Launched in 2019, Nuuly Rent is a subscription-based worn repeatedly and that customers are being more
apparel rental service whereby customers have access to thoughtful about committing to their purchases long-term
thousands of styles from over 300 brands, though and understanding if a trend is suitable for their needs,
approximately half of inventory is from URBN brands. rather than making impulsive purchases.
Customers pay a fixed subscriptions on fee of Us$88 per Gallagher says Nuuly’s buying and product care
month to rent 6 pieces, with the option to buy them while teams are in constant communication, collecting
they have the pieces at home. Unpurchased items are learnings on the impact of wear and laundering, which
returned via the pre-printed return shipping label and are passed along to URBN design teams to inform the
reusable tote Nuuly provides to customers. All items are design and durability of future garments. “We've shifted
returned to the distribution centre where they are approximately 70% of our laundering to wet washing in
laundered and repaired as needed. Nuuly has partnered our custom-built, energy- and water-efficient laundry
with small brands to remix damaged rentals and bring machines, using non-alkaline and phosphate-free
them back into the Nuuly Rent assortment as part of the cleaning solutions, that are gentler on the environment
Re_Nuuly collection, reducing clothing waste. Out-of- than household laundry detergents,” the team shared. 

circulation items from Nuuly Rent are resold through their Nuuly also repairs garments to extend their life.
resale marketplace, Nuuly Thrift, or through the sites of According to Nuuly’s Head of Product, Sky Pollard: “In
the URBN sister brands. 2022 we repaired approximately 75k garments. The
Kim Gallagher, Director of Marketing & Customer most common damage was stains (over
Success at Nuuly, says, “Our research confirmed that our 40%). Additionally, we source and replace trims like
customers were participating in the sharing economy buttons, buckles and zippers that get damaged or lost
across other industries (i.e. AirBnB, Lyft, Uber,) so we during the rental cycle. If we can't get the original trim
thought, why not fashion? We recognized this as an from a vendor, our very resourceful repairs team scours
opportunity to increase people’s access to clothes trim suppliers, and fabric stores for replacements.”

without ownership.
“We don’t believe that sustainability happens in a
According to Nuuly, out of all of the garments bought silo,” Gallagher concludes. “A cross functional task
by Nuuly Rent subscribers, ~16,000 were rented 10 or force that includes both our home office and warehouse
more times before being purchased. Becca Sandercock, teams is responsible for moving along sustainability
Strategy and Insights Manager, says, “One product was initiatives in their respective areas. We try to approach
rented 25 times before someone decided to finally our sustainability initiatives from a customer-centric
purchase it,” suggesting that rental garments are being point of view.”

Fashion Revolution Case Study For more information on how URBN brands (Urban Outfitters, Anthropologie and Free
People) perform on the Fashion Transparency Index, please visit Wikirate.org to review
their disclosures. 

To view all of the brands’ disclosing information on new business models that support
clothing longevity and slow down consumption of new clothing such as renting and
reselling, please see this link to Wikirate. 

To view all of the brands’ disclosing information on repair services in order to increase
clothing longevity and slow down consumption of new clothing, please see this link to
Wikirate. To view all other brands’ disclosures related to Overconsumption, Waste and
Circularity, please see this link to Wikirate.
Business Models of the Future 17

Resale
82 % — over the last 10 years, the amount of carbon
The second-hand clothing market is expected to grow displaced by secondhand fashion has reached 116
11 times faster than the broader retail sector by 2025 billion lbs. Much like with fashion rental, brands are
to reach a value of $77 billion, according to research looking to capitalize on the success of resale by
from ThredUp. While early pioneers of second-hand bringing it in-house. In the U.S, Eileen Fisher has led
fashion were companies like eBay, in recent years, the charge with a dedicated take-back and resale
market growth has been led by online platforms like scheme, called the Renew Initiative, since 2009. The
Depop, The RealReal, and Vestiaire Collective. brand says it’s collected 1.5 million garments since it
ThredUp estimates that buying secondhand clothing launched. Other success stories include Worn Wear
reduces the carbon footprint of a garment by up to by Patagonia and SecondHand by Levi’s.

Case Study: Reflaunt

Reflaunt is a software company that allows fashion brands, department
stores, and other retailers to participate in the second-hand clothing trade.
Backed by Madalux group, the Bluebell Group — the infrastructure in place to process single Stock
biggest distributor of luxury brands in Asia — as well Keeping Units (SKUs) or operate reverse logistics.
as Fashion for Good, The Mills Fabrica, Yellow Octopus Brands can outsource this process to Reflaunt,
and BBCapital Investments, Reflaunt helps brands to whose Software as a Service (SaaS) technology
transition to a circular fashion system by providing end- acts as the bridge between the first and secondhand
to-end support from technology modules to operational fashion sales streams. The potential to resell
management, making the implementation of a resell counterfeit items is mitigated by Reflaunt’s
service as easy as possible. blockchain-enabled technology, which reduces the
Reflaunt works with brands and retailers committed risk of this happening by tracking the origin of the
to shifting from a traditional linear business model to item itself.
a circular one. “Sustainability and profitability are not The Reflaunt team believe that more needs to be
a trade-off; transitioning towards circularity is a done to tackle the end-of-life issue that the fashion
requirement,” says co-founder Stephanie Crespin of industry has created as an outcome of the mass
Reflaunt’s brand partners, which include Net-a-porter, volume of products churned out year on year. “It starts
Mr. Porter, The Outnet, Balenciaga, Harvey Nichols, with the implementation of physical/digital IDs to track
Ganni, and Axel Arigato, among others.
the journey of all products and map out all the possible
Reflaunt addresses key issues that are barriers for end of life routes,” says Crespin. “This includes defining
both brands and consumers to partake in the resale the appropriate sales channels for products in excellent
market. This includes reducing the friction of the resale condition, upcycling routes for items that fit other types
experience, by understanding that consumer of criteria, and recycling routes if the product has
engagement with resale can be hindered by the effort reached its end of life. When items have unique
required to list an item for sale and the need to hold identifiers, it helps to ensure each item is assigned
unwanted stock in their homes.
the appropriate path to reach its destination.”

Reflaunt works with Balenciaga by implementing a Looking to the future, Crespin predicts that “all
plug-in on the brand’s e-commerce platform to create a brands and retailers will have some sort of resale
digital wardrobe for each user. This makes it easy to store service, but models will vary depending on the brand
data on their purchases, which can be used to simplify positioning, price point, and audience,” she says. “For
the process of generating listings. 90% of the information example, the resale service we deployed for Balenciaga
required to resell a product is pre-populated by Reflaunt, is different from the service we deployed for Ganni.
so customers can resell with just one click their past Brands that are already producing quality products will
purchases in exchange for money back or credits to come out of this stronger, as their customers will want
use at the partner brand.
to invest in items that retain value, and this will likely
Whilst the initiative still encourages consumption, for inform their purchase decisions.”

some customers, it is an in-road into slower consumption Ultimately, Crespin feels that innovative brands and
and engagement with the circular economy. Research by retailers that have invested in services like rental and
Reflaunt finds that 64% of their female customers have repair will shift towards a “product-as-a-service”
bought or are willing to buy secondhand fashion. Another business model, which fundamentally opposes the
key issue for brands is that many do not have the linear take-make-waste model.

Fa s h i o n R e vo lu t i o n C a s e S t u dy For more information on how Kering brands (Balenciaga, Gucci, Saint Laurent,
Bottega Veneta,) perform on the 2021 Fashion Transparency Index, please visit
Wikirate.org to review their disclosures.

To view all of the brands’ disclosing information on new business models that
support clothing longevity and slow down the consumption of new clothing such
as renting and reselling, please see this link to Wikirate.
Business Models of the Future 18

e ycle
R c

Consumer demand for recycled fabrics is rising. Not only does recycled polyester shed microplastics just
Lyst’s 2021 Conscious Fashion Report says that like its virgin counterpart, but it also can’t yet be
demand for upcycled, recycled, repurposed and recycled easily, breaking the loop on a once recyclable
reworked items on the platform jumped by 117% product (the bottle). Currently, recycling is inefficient and
year on year. But in reality, recycling textiles to create is not reducing the pressure on virgin materials.
new materials is costly, complicated, and yet to be Brands that offer take-back and recycling schemes
scaled to the necessary level for mass-market tend to work with a logistics partner, such as TerraCycle,
application. Recycled textiles come from three main Yellow Octopus, or I:CO that will collect, sort, then

sources: post-consumer textile waste, pre-consumer upcycle, downcycle, or recycle textiles. H&M runs an
textile waste like scraps, and post-industrial waste. extensive recycling programme that encourages
While polyester made from recycled plastic customers to drop old clothing at their stores. In 2020,
bottles is a popular material for swimwear and the brand says that it collected the equivalent of 94
activewear brands, it’s not without issues. million t-shirts through the programme.

Case Study: I:CO

I:CO, as part of the SOEX Group, is a supplier of global solutions for
the collection, reuse and recycling of used clothing and footwear.
I:CO collects clothing from brands and retailers than 1% of all textile waste is recycled into new
and then organises the logistics, sorting, and fibres for clothing. H&M collaborates with other
transfer of items. With roughly 7,000 collection partners to make use of the remaining 3-7%.
points worldwide, I:CO processes 200 tonnes of I:CO has recently announced a partnership with
garments daily in their facility, which is situated in Mango to ensure some textiles and footwear
Bitterfield-Wolfen, Germany. collected in Mango’s stores are distributed locally
According to I:CO, the biggest challenges within their country of collection. I:CO is currently
facing the textile market are “in the fulfilment of collecting with Mango in stores across Turkey,
our circularity ambitions because the current lack Poland, Germany and Switzerland. “This
of design for recycling and the fact that many collaboration will help to expand the Committed
interesting solutions are still in their infant stage Box project, without losing the traceability of the
means a lot of research and development is items collected, creating a positive local impact in
happening on a pilot level but is not yet scalable the different countries where the garments are
for a bigger market,” says Walter Thomsen, CEO collected, as well as optimising Mango’s reverse
logistics,” explains Beatriz Bayo Gonzalez, head of
of the SOEX Group. “This makes it harder for
sustainability at Mango.

brands to find the right partner to provide the

Since 2019, I:CO has piloted automated
exact services for their recycling needs.”
material recognition machinery. In April 2022, the
I:CO works with several of the world’s largest company announced that it will facilitate sorting
brands and retailers, including H&M to sort for its recycling partners on a larger scale. The
garments into three categories machinery determines organic molecular bonds
Rewear — clothing that can be worn again will through Near-infrared Spectroscopy and RGB
cameras which enable the recognition of the
be sold second-hand
structure and shape of items. Currently, this
Reuse — clothing and textiles that will be turned machinery is able to identify 78 types of materials
into other products, such as cleaning cloths and mixed fibers, with the ability to successively
learn more combinations over the course of its
Recycle — clothing that is turned into textile operations. “Our current set-up is able to process
fibers to be used for padding or insulation.

1,600 items per hour, which equals roughly 600 kg

per hour, depending on the types of items,” says
According to H&M, around 50 - 60% of clothes the I:CO team.

collected are sorted for re-wear and re-use and 35 - Technology such as I:CO’s automated material
45% are recycled to become products for other recognition is needed to enable fiber-to-fiber
industries or made into new fibers by companies recycling at scale, which will in turn help to combat
such as Renewcell or Infinited Fibre. However, it is the amount of global clothing waste and its social
important to acknowledge that at present, less and environmental impacts.

Fashion Revolution Case Study For more information on H&M and Mango perform on the 2021 Fashion Transparency
Index, please visit Wikirate.org to review their disclosures.

To view all of the brands’ disclosing information on new business models that support
clothing longevity and slow down the consumption of new clothing such as renting and
reselling, please see this link to Wikirate. To view all other brands’ disclosures related to
Overconsumption, Waste and Circularity, please see this link to Wikirate.
Scaling Traceability 19

Scaling Traceability
recycled into new textiles. Increased transparency
A 2019 McKinsey survey of sourcing executives
on what happens to clothes received through take-
found that 65% expected to achieve full traceability back schemes is needed to help reduce the amount
from fiber to store by 2025. To achieve this, not of waste sent to landfills. Embracing traceability at
only do we need to see an ambitious rate of scale means investing in the circular economy.
investment, but a complete system redesign that To achieve an economy where little is wasted
holds brands and retailers accountable for their and clothing stays in use for longer, consumer
commitments. adoption is crucial. Whether that’s buying second-
According to the 2021 FTI, 32% of brands have hand and renting clothing, or disposing of clothing
permanent, year-round take-back schemes, but through take-back schemes and donation
only 22% of brands disclose what happens to initiatives, there is no circular economy without the
clothes received — i.e how much is resold locally, participation of the business sector, consumers,
resold into other markets, downcycled, upcycled, and governing bodies.

Case Study: adidas

Global sports brand adidas is one of the first large

businesses in the footwear and apparel sector to achieve
material traceability at scale, gaining greater visibility into
its complete supply chain down to the material level, by
using TrusTrace’s digital traceability platform.

As part of a commitment to sustainability, everything has been produced as planned, and

adidas has set targets to source 100% recycled can then easily provide evidence for product or
polyester, the most common material used in material claims.
adidas products, by 2024. By 2025, adidas is j
With ob ectives to trace all products
also aiming for 9 out of 10 of their articles to be and materials across apparel, footwear, and
sustainable, meaning that they are made with accessories divisions, adidas had to ensure that
environmentally preferred materials. adidas is the traceability solution could cover large amounts
leveraging material traceability to track and of data, meaning a digital, automated, and
create a digital chain of custody for the use of scalable solution. With many transactions and
certified materials, such as organic cotton or data points from multiple systems, manual data
recycled polyester, in every batch of production entry was not an option.

across its supplier network. Therefore, adidas integrated their systems with
U sing material traceability data, adidas the TrusTrace platform, ensuring seamless data
has achieved better visibility and control of fl PL P
ow between systems such as a M, urchase
their supply chain data, and can ensure that O rder System, and Supplier Management
compliance needs are met. adidas collects all fl
systems. Besides automated data ows, the
the supply chain data in real time as the q
integrations also ensure data uality, as the data
fl
materials ow through the value chain, meaning is continually updated, capturing last minute
that the final product has all the data attached to changes to designs or purchase orders. Through
it when it arrives on the market. With this data, a strong focus internally and in collaboration with
adidas checks the finished product vs. the their suppliers, adidas was able to implement and
/
original design purchase order, ensuring that scale the traceability program within months.

TrusTrace Case Study

TrusTrace Case Study: adidas 20

Case Study: Gucci

Gucci has several circularity initiatives aimed at addressing each
stage of the value chain. Beginning in 2016, Gucci was the first
luxury brand to use Econyl®, a nylon yarn made from pre- and
post-consumer waste such as discarded fishing nets and carpets.

This led to the release of Gucci’s Off the Grid To address circularity at the raw material level,
collection, which uses Econyl® as the main Gucci is working to improve biodiversity through
material. The partnership expanded in 2018 a Natural Climate Solutions Portfolio, which is
to include a ‘GUCCI-ECONYL® Pre focused on protecting forest biodiversity,
Consumer Fabric Take Back Programme safeguarding and restoring mangroves from
whereby Gucci suppliers recover ECONYL® deforestation, and investing in regenerative
regenerated nylon offcuts from Gucci’s agriculture within Gucci’s supply chain.
production to be re-made into yarn. The brand incentivises farmers to shift to
To address post-production waste, the regenerative practices through carbon farming,
Gucci-Up project is focused on the recovery which optimises carbon capture on working
and use of leftover and discarded materials to landscapes by implementing practices that
decrease dependency on new and natural improve the rate at which CO2 is removed from
resources. To help in this effort, Gucci works the atmosphere and stored in plants and soil
with Green Line, a company specializing in the organic matter.

Gucci’s latest initiative is Gucci Vault where

collection and recycling of textile scraps.
the “emotional durability” of garments is at the
Between 2018 and 2021, 445 tonnes of
centre. Gucci Vault restores vintage pieces and
scraps were collected from Gucci’s suppliers integrates them with modern elements and also
and re-purposed into new garments. Through platforms the work of a cohort of designers
this initiative, Gucci engages with NGOs selected by curator Alessandro Michele,
focused on the empowerment of women for whereby designers must abide by Kering’s
the regeneration of the offcuts, as well as with code of conduct on sustainability, ethics and
social cooperatives in Italy to support the quality. Gucci’s initiatives address different
training and community reintegration of stages of the value chain, from raw material
people from marginalised groups. level through to a garment’s end-of-life.

Fashion Revolution Case Study For more information on how Kering brands (Gucci, Balenciaga, Saint Laurent,
Bottega Veneta,) perform on the 2021 Fashion Transparency Index, please visit
Wikirate.org to review their disclosures.

To view all of the brands’ disclosing information on new business models that
support clothing longevity and slow down the consumption of new clothing such
as renting and reselling, please see this link to Wikirate. To view all other brands’
disclosures related to Overconsumption, Waste and Circularity, please see this
link to Wikirate.
Standardizing & Decentralizing Data 21

Standardizing

& Decentralizing Data

Experts agree that the For example, cotton can be certified by the
GOTS, the Organic Content Standard (OCS), 

transformation of the fashion or the BCI. These cover raw material claims like
industry centers around accurate, social and environmental impact, but when it
comparable, and granular-level comes to siloing these certifications into specific
concern areas, the lines are blurred. This makes
data. “Credible and robust data it even more complex for businesses trying to
needs to form the foundation of any implement Environmental, Social and Governance
(ESG) measures.
sustainability commitment,” says The challenge is establishing a common
Amina Razvi, executive director at definition of sustainability, understanding how
the Sustainable Apparel Coalition. different standards bodies are addressing
sustainability from different angles, and how
“If organizations are promoting green credentials all these players can exchange information so
to customers and stakeholders, it is vital the that brands can easily consume data. Common
action sitting behind these claims stands up to identifiers for suppliers have to be established so
scrutiny. Without the metrics in place, it’s just that multiple systems auditing different issues
marketing spin.” within the same facility can exchange and collate
Initially, data can be used to benchmark information. Open Apparel Registry and GS1 are
among the organizations that are establishing this
and track changes, says Razvi. “Empowering
crucial common language so that data can be
organizations to understand the impact they are
captured and shared accurately and efficiently.

making, across their whole supply chain, is

“Standardized tools enable effective and
central to improving,” she says. “Data is a
comparable measurement, helping business and
powerful decision-making tool. It’s the tool that consumers make more informed choices,” says
in-house sustainability teams need to build a Razvi. “Industry transformation can be achieved
strong business case for prioritizing purpose through collaboration with leaders, challengers,
as well as profit. It can help leaders make influencers and experts around the globe.
fundamental decisions to create new processes Standardization helps ensure everyone is on the
or make changes that are better for people same page with achieving the highest standards
and the planet.”
of social and environmental performance.”
The proliferation of auditing bodies and
certifications attempting to define sustainability It’s important for all organizations 

and social standards in the fashion industry has to be able to access clear, credible 

created a landscape that lacks a common and scientifically rigorous data to
language. In order to streamline, communicate, support them in measuring the impact
and optimize the data collected by different of their whole supply chain. Greater
auditing groups, standardization is key. traceability across the industry will
Competing standards bodies with incompatible drive change, especially when it
data create a headache for fashion businesses comes to empowering consumers to
attempting to comply with regulations. “One of make more informed buying choices.
the biggest challenges our industry faces is the
lack of standardized data to inform insights and Amina Razvi
collective action,” says Razvi. “If we want to Sustainable Apparel Coalition
achieve change, we need a coordinated
approach.”
Standardizing & Decentralizing Data 22

Decentralization looks at the ownership of data. In data to authenticate goods. Decentralization

a traditional supply chain, this data is centralized. uses blockchain to ensure that there is no single
For example, in the production of a t-shirt, the authority controlling the maintaining the ledger of
brand producing it would own the data about how all the transactions. When data is decentralized,
it was made, and then the retailer that sold the t- it is democratized. But data doesn’t exist in a
shirt would own the data relating to the batch. vacuum — developments in traceability are
The problem occurs at the end of a product's informed by trends within the fashion industry
life when it finds its way to a recycling facility. The as well as global economic and cultural shifts.

brand no longer owns the data relating to that t- The value that digital traceability data can
shirt, so the recycler may struggle to determine bring to a business should not be underestimated.
the materials (it’s also common for garments to be According to Bain & Company’s Hernan Saenz,
mislabelled, concealing their true composition), “data allows companies to make predictions,
making it challenging to recycle. Therefore, run scenarios, identify unnecessary resource
decentralization is crucial to the success of consumption, respond faster to changes in
circularity, because it accounts for the fact that demand, and minimize the impact of internal
a product and its data will live longer than the and external shocks.” He says. “These combined
ownership of the product.
benefits will translate into higher growth, lower
When data is decentralized, it is attached to the costs, increased market share, better return on
product, rather than to the owners of the product. investments, and, overall, an improved return
It’s not just applicable to the end of life, but to the to all stakeholders.”
booming resale market, which increasingly uses
Materials,
Innovation &
Collaboration
Materials, Innovation & Collaboration 24

Materials, Innovation & Collaboration

Between 2017 and 2019, there was a 5x increase in the number
of “sustainable” fashion products launched onto the market.

Most often, incorporating a percentage of materials are sustainable and which are not
eco-friendly materials is the defining feature of a isn’t as straightforward. There is no clear cut
sustainable product, so it makes sense that when separation of ‘good’ and ‘bad’ materials —
consumers think about a sustainable product, they all have benefits and drawbacks. It pays
environmental impact is top of mind. For to be aware of the environmental and social
businesses, introducing sustainable materials
impact concerns linked to the materials you
into their product offering is often at the core of
choose for your business.
their sustainability strategy. But defining which

Defining Sustainability
By Fashion Revolution

The surge in so-called sustainable schemes, but the majority have been found

to be unambitious and untransparent which

materials, fibers and textiles has
leads to some brands not addressing critical
brought with it a plethora of new issues like fossil fuel reliance, microfibers,
terms, certifications and definitions overproduction and end-of-life issues — all

of which are key areas to be considered

in the fashion industry, leading to with regard to sustainability.

challenges in how exactly to define The FTI 2021 found that while 44% (110
sustainability. The term ‘sustainable’ 5
out of 2 0 brands) disclose a time-bound and
measurable sustainable materials strategy,
lacks legal protection and is roadmap or targets, less than 1% of brands
disclose the percentage of workers in the supply
ambiguous in its definition. chain receiving a living wage. This suggests that
brands have a tendency to separate workers’
Ultimately, this allows some brands to lead with rights and well-being from environmental issues
vague and unverified claims. The 2021 edition of when in reality, they should be considered in
the Fashion Transparency Index (FTI) found that tandem. There is no sustainable fashion without
nearly half of major brands and retailers (44%) .

fair pay
publish targets on sustainable materials, yet Brands must move on from focusing primarily
fewer than one-third (30%) define what on materials and recast their attention and
constitutes a so-called ‘sustainable’ material. resources toward the people who make their
Overwhelmingly, brands do not have an agreed, textiles and garments, too. Ultimately, any claim
consistent definition of sustainability or how it is of sustainability must encompass both social
enacted in practice. Some use certification W
and environmental aspects. ithout a concrete
Defining Sustainability by Fashion Revolution 25

understanding of sustainability, it becomes fashion’. Sustainable fashion should be the

challenging to trace the social and environmental norm, not the exception. In order to achieve
impact of supply chain materials and practices. this, the burden of proof must be placed on
Variances in how we define and conceptualize companies through compliance and regulation,
sustainability means that there is an and not solely through certification schemes.
inconsistency in how data is recorded and Although we cannot underestimate the power
shared, if that is done at all, which can delay of individual actions on a collective scale, the
necessary and meaningful actions to remediate ultimate responsibility lies with brands and
issues. Inconsistent metrics makes it challenging retailers as the power brokers in the industry
to compare and contrast between brands, while who should not be producing unsustainable
the influx of ‘sustainability’ accreditation across products to begin with.
various materials and textiles leads to confusion,
At COP26 in November 2021, Fashion
as consumers attempt to make informed
Revolution signed an open letter organized
decisions about the clothes they choose to buy
by Textile Exchange where we urged
and how best to care for the clothes they own.
policymakers to consider working with the
The swell of sustainability claims makes it feel
apparel, textile, and footwear industry to
as though sustainability itself is both everywhere
develop thoughtful trade policy mechanisms
and nowhere at once. Considering the variance
to drive the uptake of environmentally
in how it is interpreted and the lack of legal
preferred materials.

protection on the term itself, the door is wide

open for greenwashing. According to market Such mechanisms can be leveraged to
research undertaken by Changing Markets drive increased uptake of environmentally
Foundation, out of 4,000 products from 12 online preferred materials by mitigating the price
shops they analyzed, 59% of products that premiums that are currently a significant
brands called sustainable were deemed to be barrier for many companies, potentially
misleading or unsubstantiated. Often, brands are making preferred options more favorable
claiming products as sustainable when in fact than — or at least equal to — their
just one component part of the end-product is conventional, more impactful counterparts
considered sustainable rather than the item in from a cost perspective. With all levers being
its entirety.
pulled simultaneously across individuals,
Ultimately, it is imperative that we move brands and policies, we can land on a more
beyond the binary of fashion and ‘sustainable
standardized vision of sustainability and
implement the right processes to ensure it.
Textile Trends 26

Textile Trends
Next-Gen Materials While providing a glimpse into the future of
materials, many innovative materials are not
According to the Material perfect replacements for their traditional
counterparts. For example, many plant-based
Innovation Initiative (MII), next-gen leathers use petroleum-based resins and
materials are “livestock-free direct chemical binders, making them non-
replacements for conventional biodegradable. In addition, few have reached a
commercial scale of production, which prevents
animal-based leather, silk, down, fur, them 
 from taking a larger market share.
wool, and exotic skins…[that] use a “The current challenge in the industry is
variety of biomimicry approaches lack of supply of next-gen materials, not lack
of demand,” says Rawlings. “In order for the
to replicate the aesthetics and fashion industry to use more sustainable and
performance of their animal-based animal-free materials, those materials need to
counterparts.” It’s a booming meet the industry’s performance, aesthetic,
market. price, and volume requirements.” MII expects
that next-gen materials will make up 3% ($2.2
The MII surveyed 40 leading fashion brands and billion) of the materials market by 2026.
found that 38 of them were actively searching for
next-gen material alternatives. “There has been
an increase in the number of partnerships With the continued growth in the
between brands and next-gen material next-gen materials, the fashion
companies,” explains Nicole Rawlings, co- industry has the opportunity to make
founder and chief executive of MII. “Our Brand
significant headway in reducing its
Engagement Report, published in February 2022,
environmental footprint. Brands need
highlights over 110 partnerships between brands
to respond to consumers who have
and next-gen material companies. We are also
indicated clearly that they are ready
seeing more financial investment by brands in
material companies and even a handful to support this positive change.
developing materials in-house.”
Since 2014, 42 next-gen material companies Nicole Rawlings
have been founded, totalling 74 around the world Material Innovation Initiative
in early 2021. Next-gen materials come from a
wide variety of sources, from the fungal species
mycelium (Mylo™ Unleather by Bolt Threads) to
grape skins (Vegea), pineapple leaves (Piñatex® by
Ananas Anam), algae (Bloom by Algix) and many Plastic-free Fashion
more. There are even companies bioengineering
animal cells to create lab-grown leathers (Modern Since the mid-1990s, synthetic
Meadow and VitroLabs), furs (FUROID™️), as well
as turning carbon emissions into carbon-negative
fibers have dominated the textile
textiles (Rubi Laboratories). Leather alternatives are market. In 2020, polyester alone
by far the most common category of next-gen made up 52% of the market.
materials, says Rawlings. “In April 2021, there were
around 49 companies developing next-gen leather, Synthetic fibers, as well as the plastic used

increasing to 67 by the end of 2021, while in April for packaging and transporting clothing, are
2021, only nine companies were focused on predominantly derived from fossil fuels, which
biomimicry of silk, seven on wool, six on down, consequently leach chemicals and shed
five on fur, and one on exotic skins.” microplastics into the environment.
Textile Trends 27

It’s estimated that there are 14 million Regenerative Agriculture and

tons of plastics on the ocean floor, and Biodiversity
without divestment by 2050, there will be
more plastic in the ocean than fish (by Loss of biodiversity is inherently
weight). According to the 2021 FTI, linked to the climate crisis.
although just 25% of brands publish a
Toxic chemicals, monoculture farming, water
measurable, time-bound target to
contamination, and deforestation all damage the
reduce the usage of fossil fuel-derived
biodiversity of the natural world and erode soil,
textiles, even less (18%) publish which is crucial for absorbing carbon and
progress on this. filtering water. In 2014, the Food and Agriculture
In an effort to shift the fashion industry Organization of the United Nations predicted that
away from its reliance on fossil-fuel at the current rate of destruction, there could be
plastic, industry groups have proposed only 60 years worth of topsoil left on earth. This
taxing the production of virgin plastics. is a huge concern for the fashion industry, which
This was one of the key recommendations relies on agriculture for key materials like leather,
to come out of Changing Markets’ 2021 cotton, wood pulp (for man-made cellulosic
report Synthetics Anonymous (which also fibers) and wool.
suggested disincentivizing the use of Brands must track and audit their supply
plastic waste like water bottles as a chains in order to understand where the
biodiversity risks are, and how they can source
feedstock for polyester production), as
natural materials in a way that gives back to the
well as the 2019 Fixing Fashion report in
planet, rather than just extracting from it. Brands
the UK. While the recommendations that are well aware of the urgency: 59% have made
were laid out by the Fixing Fashion public commitments to address biodiversity risk,
committee were rejected, criticism of the but only 8% of companies have an explicit
oil and gas industry is increasing, putting biodiversity strategy, according to the 2021
pressure on all businesses to find plastic- Biodiversity Report by Textile Exchange. Industry
free textile alternatives. initiatives like the Fashion Pact, founded in 2019
with 3 pillars — climate, oceans, and biodiversity
— are focused on agricultural investments.
By 2025, the group aims to support zero-
deforestation and sustainable forest management.
Material Glossary 28

Material Glossary
Global fiber production has almost doubled in the
last 20 years — in 2020, 109 million tonnes of fiber
were produced.

Textile Exchange expects this number to rise involved with the most popular materials
by 34% to 146 million tonnes by 2030. It’s categories. All materials have the potential
crucial that fashion businesses understand to pose environmental and social risks, so
the risks hidden in their supply chains, which businesses should investigate these
will be different for every material group that thoroughly and not rely solely on
they source from. Below, we’ve identified the certifications or supplier guarantees when
major risks, certifications, and best practices looking into their material supply chains.

Material Market Share* Risks Certifications Best-Practice

Synthetic 57.6% High fossil fuel use & GHG emissions;

OEKO-TEX®
Recycled or bio polyester
Fibers pollution of marine habitats; use of STANDARD 100
(polyester & hazardous chemicals; shedding of
nylon) microplastics

Cotton 23.7% Energy-intensive harvesting and ginning; BSCI, SMETA, STe by P Fairtrade cotton; recycled
chemical-intensive finishing process; water OEKO-TEX®; HIGG, SA cotton; naturally colored
consumption & contamination; soil 8000; BCI; Cotton Made in cotton
degradation; GHG emissions turning yarn Africa; Cleaner Cotton ™
into fabric; forced and child labor in supply
chains

Leather 6.6% Overgrazing causing soil erosion; animal WRAP; Leather Working Certified chrome-free or
welfare; high water and chemical use; Group (LWG); QUIMA; vegetable tanned leather
q
inade uate personal protection for workers Eurofins, CSBC; OEKO-
in the supply chain; loss of traceability due TEX®
to complex supply chain; deforestation of
ancient and endangered forests

Man-Made 4
6. % Illegal logging & deforestation of ancient P
FSC; EFC; Canopystyle :
Tencel lyocell, Re newcel l

Cellulosics and endangered forests; toxic chemical- P U

Audit; SB ; E Ecolabel; EvrnuFiber ™

q
intensive processing; inade uate personal HIGG; RSC Refibra™

protection for processors Orange Fibe r

L
And Modal from enzin g

V
Birla Eco iscose

Organic 1% Fraudulent organic certifications; GHG Fairtrade Organic; GOTS; Certified organic cotton
Cotton emissions turning yarn into fabric Organic Content Standard;
W : 9U
ISO I A 32 201 ; SDA
Organic

Wool 1% Land desertification through overgrazing; Woolmark; Responsible W

R S certified wool; OCS
animal welfare; mulesing; GHG emissions Wool Standard (RWS); organic certified wool;
from grazing livestock Certified Wildlife Friendly; Cloudwool®
Land to Market; GOTS

* Market share size according to findings by the Textile Exchange.

Certification Challenges 29

Certification Challenges
In recent years, certifications 

have grown in popularity as
brands have faced increased levels
of scrutiny over their sustainability
claims. Certifications provide a
tick of approval, which can signal
to consumers that a brand is
committed to investing in
sustainability.
“As campaigners and members of the public
raise questions about fashion, brands want
a short answer. That is most easily done
with certification logos,” says Paul Foulkes-
Arellano, founder and circularity educator at
Circuthon Consulting.
“The downside is the sheer number
available,” says Foulkes-Arellano. “How do
you begin to choose the most important
ones? Some brands plaster a whole row of
certifications on the hangtag — quantity, not
quality seems to be the name of the game.”
0 M L
A 2 22 report by Changing arkets, icence
G
to reenwash, has shone a spotlight on ten
It’s good that certifications are of the most popular certifications, concluding
becoming more and more desirable. that they “enable the proliferation of
But who is certifying the certifiers? ‘ ’
greenwashing on a remarkable scale …
Where is the quality control? Anyone M fl x
oreover, the level of in uence e ercised by
can set up a certification body and fashion brands in these initiatives and the
start charging money – and frankly, lack of any independent oversight, inevitably
many certifiers don’t understand the means that they end up promoting industry
full ecosystem in which fashion W
interests.” hat this means for fashion
operates. There is no external brands that rely on certifications to bolster
scrutiny, no contextualization, as sustainability claims is not yet clear. The fact
technology permits more rigorous is, traceability technology solutions are only
standards to be achievable. M
as accurate as the data being input. ore
collaboration is needed between auditing
bodies, certifiers, brands, and legislators.
Paul Foulkes-Arellano
Circuthon Consulting
The value of accountability and scrutiny
has never been more evident.
Recyclable vs Recycled 30

Recyclable vs Recycled
The circular economy hinges on recycling. For both chemically and

making clothing with recycled mechanically recycling of fibers, the feedstock

materials, as well as designing is needed in well defined and steady flow.

This provides particular challenges to sourcing

for recyclability. feedstock of post-consumer textiles as
infrastructures are still being optimized.”
Many brands have committed to replacing
“Products that are designed with recycled
virgin synthetics with recycled alternatives,
inputs are using materials that have been
but in 2021, Changing Market’s Synthetics
recovered from either a pre- or post- Anonymous report found that only a handful
consumer waste stream and processed of leading brands are actually investing in
into recycled fibers,” explains Ina Budde, fiber-to-fiber recycling technology.
co-founder and chief executive at Berlin Currently, most textiles get downcycled into
start-up circular.fashion. lower-value products like insulation, mattress
fillings, and industrial cloth wipes, not turned
into new clothing. Mechanical recycling shortens
“Whereas designing a product for future the length of fibers, meaning that in order to
recyclability enables the product and all its create a usable yarn, it has to be blended with
components to be regenerated to a material
longer, stronger virgin fibers.

of high quality able to be used in textiles and While the recycled textiles market is small,
clothing again.” it has huge potential for growth. Many solutions
The recycling industry faces a number of are still in their pilot phase; however, companies
challenges. While some materials are indeed like Worn Again Technologies, Renewcell,
recyclable, global infrastructure is not sufficiently Infinited Fiber Company, and Ambercycle are
equipped to deal with the scale of recycling closing the gap between trial stages and
needed to significantly reduce the amount of commercial scalability. Legislation is also
clothing heading to landfills. “Today, there is driving this forward — the 2022 EU Strategy for
a lack of full-scale infrastructure for recycling,” Sustainable and Circular Textiles envisions that
says Budde. “Volume and availability of by 2030, all textiles in the EU market will be
regenerated materials is scaling up, but is recyclable and made from recycled fibers.
still in development.”

Of all the textiles produced in 2020, only

To foster a circular economy, products
8.1% came from recycled materials like PET
are ideally made from safe, recycled or
water bottles or pre/post-consumer textiles.
renewable inputs, as well as designed
When it comes to the capabilities of recycling
infrastructure, “blended materials, attached for longevity and recyclability.
trims and metal hardware can pose a
challenge,” explains Budde. Adding to this, Ina Budde
“the majority of products today do not have circular.fashion
a passport and product ID to ease the data
transfer and enable intelligent sorting for
Recyclable vs Recycled 31

Case Study: 

The Circular Fashion Partnership
The Circular Fashion Partnership (CFP) is a global initiative
spurring on local action in textile manufacturing countries to
accelerate and scale recycling of post-industrial textile waste.
The ambition is to achieve a long-term, scalable, and just
transition to a circular fashion industry.

The project facilitates circular commercial and high quality textile waste streams that
collaborations between global fashion brands, form perfect feedstock for textile recyclers.
manufacturers, and recyclers to enable and Through the Reverse Resources platform,
incentivize segregation and digital tracing of the CFP was able to track over 100 tonnes
post-industrial textile waste to recycling of textile waste to suitable recycling solutions.
solutions. The first CFP was initiated in 2020 Furthermore, several brand participants were
in Bangladesh by Global Fashion Agenda, able to go one step further and present the
together with the Bangladesh Garment journey of their products made with recycled
Manufacturers and Exporters Association materials all the way to their end users.
(BGMEA) and waste traceability platform “Within the Circular Fashion Partnership, it
Reverse Resources with support from was through the digital platform of Reverse
Partnership for Green Growth (P4G). Resources that we were able to connect
Being able to identify and digitally trace waste to recycling solution and present the
post-industrial textile waste streams, is critical multi-million dollar opportunity of recycling
to being able to unlock the opportunities of textile waste domestically,” says Syrett.
circular business models within manufacturing By tracing and presenting textile waste
countries. “Digital traceability is a critical enabler streams, the CFP is not just matching
for the circle economy, and we believe has an feedstock supply of recycled materials with
important role in achieving a just transition and global brand demand, but also presenting
distributing value fairly across all actors,” says opportunities at scale to increase awareness
Holly Syrett, director of impact programmes & and create a conducive environment for
sustainability at Global Fashion Agenda.
circularity. In Bangladesh, Reverse Resources
There’s a significant demand from global estimated it could reduce its virgin cotton
fashion brands for recycled textiles, yet a very imports by 15% and save $500 million USD
limited supply. Manufacturing countries such as a year, by recycling its 100% cotton offcuts
Bangladesh have large quantities of consistent domestically.

Case Study
Material Misconceptions 32

Material Misconceptions
What do these facts have in leathers on the market are polyurethane (PU)
common? Fashion is the second or polyvinyl chloride (PVC), both made from
toxic chemicals that are dangerous for the
most polluting industry in the world. planet and to human health throughout not
It takes 1,800 gallons of water ​to only the production, but also for use-phase,
create a pair of blue jeans. 20% of and end-of-life stage too.
There are many material misconceptions
global industrial water pollution about cotton, and one of the biggest is that it’s
is from the fashion industry. a water-thirsty crop. In 2021, Transformers
Foundation published Cotton: A Case Study in
The answer: they’re all false. Inaccurate statistics
Misinformation with the aim of debunking four
have been swirling around the internet for years,
common beliefs about the fiber. The report
used liberally for their shock value by those
found that while it is true that cotton is often
trying to communicate the scale of fashion’s
grown in water-stressed regions of the world,
impact on the environment.
the term “thirsty crop” is an oversimplification
Attempts to verify these statistics have been
of the issue. “The relationship between
unsuccessful. Journalist Alden Wicker debunked farming, cotton, and sustainable water
these facts in 2017 for Racked, then others in
management is complex,” reads the report.
2020 for Vox after seeing false statistics “Calling cotton — a plant that’s grown in arid
continue to be shared far and wide despite
regions because it's drought-tolerant — water-
being proved incorrect. “If we’re serious about thirsty is misleading and can lead consumers
recruiting the fashion industry into the fight to
to villainize a crop or a fiber rather than open
save our world from burning, these bad facts do up a conversation about water stewardship
us all a disservice,” she wrote. “They allow
and sustainability in the cotton sector.”

brands to wave vaguely at reducing their impact Considering the prevalence of

without taking meaningful action. And they
misconceptions about materials, and no
stymie the ability to implement meaningful clear answer as to which materials are “good”
regulation, which needs to be undergirded
or “bad”, how will the industry know the right
by solid data.”
way forward? The key is to test different paths
Proliferating misinformation leads to
while gathering data to understand which
misconceptions that pose a serious threat to solutions provide less impact and enable
progress, embedding illinformed assumptions
longer useability. Collaborating as an industry
into the consumer’s mind. In 2021, e-commerce to continuously innovate will be paramount.
platform Lyst recorded a spike of 178% in
The good news is there’s a lot happening in
searches for vegan leather, as many consumers this space, as you will learn about in the next
assume that “vegan” or “animal-free” leather is
section on traceability innovation.
a more sustainable, ethical alternative. What
consumers aren’t told is that most vegan
Traceability Innovation By Fashion for Good 33

Traceability Innovation
By Fashion for Good

From the Fashion for Good innovation perspective, there are

two main categories of traceability solutions: Traceability
Platforms and Tracer Technologies. Based on the ESG and
business relevance of traceability, the demand for supply
chain traceability platforms is growing. Traceability
platforms are made up of two main sub-categories:

Traceability Platforms: 
 Traceability Platforms:

Supply Chain

Circularity

These are blockchain or cloud-based solutions These aim to digitize the operations of a product
that provide digital supply chain mapping and once it has been created, facilitating an effective
visualization tools, and perform material, batch, post-gate circular economy. This allows the
and product traceability alongside facility communication of supply chain data points to
profiling. They are used to consolidate and verify consumers and end-of-use users, via digital
chain-of-custody documentation (transaction product passports which facilitate key use
certificates, scope certificates and associated cases for brands: Product authentication,
sustainability standards), and allow Automated anti-counterfeiting, re-commerce, re-sale, and
Programming Interface (API) integration with visibility of material composition for sorting and
brands/suppliers internal systems. The supply recycling purposes. The supply chain scope for
chain scope for these solutions are scope three/ these solutions are gate to cradle/tier-zero
cradle to gate/tier four to tier one. onwards (post-use phase).
For supply chain traceability platforms, a key
distinction is between fiber forward and garment
backward approaches. Service providers with Tracer Technologies
fiber forward capabilities allow for real-time and
secure digital identities to be created in parallel Current methods of commodity and information
to the commodity flow. Garment backward exchange in the fashion supply chain don’t
solutions follow a more traditional approach, always provide adequate levels of verification
mapping the supply chain from the finished beyond digital or manual exchanges of chain-
garment backward, usually using a brand’s of-custody documentation. Within certification
purchase orders as the data pivot to map schemes, chain-of-custody methods include
product origins.
verification at site and transaction level, but
These approaches can be implemented without physical verification of the fibers/
in tandem across different supply chain scopes materials themselves.
of focus within a brand's scope three supply Widely incentivized by motivations to provide
chain. For fiber forward approaches, blockchain increased traceability confidence to fiber types
is utilized for the operational agility it can and certifications, alongside incoming corporate
facilitate: live visibility of product flow, legislation in sourcing regions (e.g. the US
trustworthiness for corporate disclosures, and Uyghur Forced Labor Prevention Act and the
incoming EU directive on Corporate
accurate mathematical calculations between
Sustainability Due Diligence), the demand to
facilities (or “blocks” on the chain) for waste
integrate tracer technologies into global fashion
stream analytics, volume reconciliation, smart
supply chains has risen at a fast pace.
contracts, and inventory management.

Read about Fashion For

Good’s Tracing Sustainable
Viscose Pilot here
Traceability Innovation By Fashion for Good 34

The ability to prove geographic and supply 
 chain and geographic origins. Forensic 

chain origins of sourced materials, and provide Tracers have off-site detection and no need for
physical verification (in tandem with site and application of any substance or marking onto
transactional documentation) are essential fibers, yarns, or materials. For the user, their
capabilities for supply chain traceability implementation has less supply chain operational
platforms to have. This integrative capacity with workload and burden. They are useful to facilitate
tracer technologies can strengthen sustainability ad-hoc “spot checking”, indicating with
claims, showcasing that being ‘tracer agnostic’
confidence that the fibers sourced meet desired
is a central feature of importance for traceability
sustainability criteria, and helping to red-flag
solutions looking forward.

questionable geographic sourcing areas (e.g.

Tracer technologies are made up of three 
 forced labor concerns). In addition, they are used
sub-categories: to communicate the authenticity of premium and
preferred sustainable fibers (e.g. organic supima
Additive Tracers: These are physical cotton).
additives which are applied to the fibers With a smaller range of Tracer Technologies
and materials on the supply chain floor, available in the Forensic Tracer category
and detected later to prove origin.

(compared with Additive Tracers), their usability
Forensic Tracers: Technologies that focuses on transparency of first-mile origins of
analyze the micro-particle and natural fibers, rather than physically and digitally
biochemical composition of fibers and tracking product flows in real-time throughout all
materials in order to prove origin.

tiers of the supply chain. Additive Tracers bear
more supply chain operational work for
Tags: Near Field Communication (NFC) and implementation and maintenance, as they have
Radio Frequency Identification (RFID) tags on-site application and detection processes.

are used more for commercial shipping Supplier engagement and management is a
and logistics. These are not focused on the key prerequisite to enable the sound operational
upper stream supply chain but rather used performance and logistical maintenance for
on finished goods and downstream on Additive Tracers on the facility floor. They hold
shipping pallets and boxes. more flexibility for the user to provide traceability
integrity based on wider supply chain operability
Both the Additive Tracer and Forensic 
 and coverage for a larger scope of supply chain
Tracer sub-categories are used to trace and tiers and fiber types. As the title suggests,
authenticate fibers and materials, proving supply Additive Tracers are applied onto fibers and

Traceability Innovation

Traceability Platforms Tracer Technologies

Supply Chain Circularity Forensic
 A dditive
 Tags

Tracers Tracers

Supply Chain
 Re-commerce NFC

Mapping Isotope A rtificial DNA

Product
 Sorting/Recycling lemental Profiling

E Optical Fingerprints RFID
Traceability

DNA Analysis Ink/Micro-Particle
 QR Codes

Fluorescents

Microbiome

Part of Fashion for

Good’s Organic Cotton
Traceability Pilot
Traceability Innovation By Fashion for Good 35

materials, existing physically within the fiber 
 motivations to digitize supply chain data 

or material traced. This physical traceability 
 across industries for supply chain management
runs in parallel to digital traceability. Many of 
 purposes: ESG improvements, supply chain risk
the Additive Tracer companies have their own assessment, inventory and capacity planning,
proprietary IT system to facilitate data uploads and financial forecasting. On the contrary, 

and analysis from detection processes that
there has been a smaller number of Tracer
‘checkpoint’ the fiber or material through supply
chain tiers, since the point of application. With a Technologies that have matured. This is mainly
wider range tracer technologies available in the due to the delayed business case for physical/
Additive Tracer category, their usability is more material level traceability verification, and 

flexible, based on wider claimed supply chain the greater difficulty implementing such
operability and coverage. They hold a focus on technologies compared to improving 

physical tracing of fibers and materials, and the digital traceability and inventory control.
associated digital capabilities for data uploads, From Fashion for Good's perspective,
real-time tracking, and analysis. This allows for in order for brands to achieve traceability
an innovative synchronization of the physical excellence, three levels of verification need
and digital traceability worlds. to be realized and maintained.
Overall Tracer Technologies have the
capability to provide physical verification for
fibers and materials in parallel with chain-of- First Step: Digital Traceability
custody traceability. This allows for
In collaboration with the selected supply chain
Manufacturers, brands, and retailers to more
traceability platform:
confidently verify chain-of-custody claims,
and consumer-facing sustainable product Perform transactional-level verification
communication via product traceability, tracking product
journeys either by fiber forward or garment
Reduction of auditing and supply chain risk backward approaches
assessment through authorized relationships
between tracer technologies, suppliers, Perform site-level verification by creating
brands, and certification bodies visibility and engagement with your supply
chain landscape and facilities.
The incentivization of suppliers and
manufacturers to meet the criteria of
sustainability standards and certification Second Step: Physical Traceability
more rigorously, by identifying and flagging
certificate counterfeiting. In collaboration with selected tracer
technology, (if required) perform physical/
material-level verification of sustainable
Conclusive Thoughts and preferred fibers.

In the traceability innovation landscape, we have The harmonization of digital traceability with
seen an increase in the number of innovators physical traceability rests on the agnostic and
emerging in the Supply Chain Traceability integrative capabilities between Supply Chain
Platform Space. This is due to the widespread Traceability Platforms and Tracer Technologies.

Read about Fashion For

Good’s Organic Cotton
Traceability Pilot here
Supplier Investment & Collaboration 36

Supplier Investment & Collaboration

Sustainable Financing says Rogier van Mazijk, investment director at
Fashion for Good. “Financing of sustainability
is, however, not limited to the financing of
In order to see significant shifts
disruptive innovation, but also includes other
in the industry, Fashion for Good initiatives and the further adoption of already
estimates that $20 – $30 billion in existing solutions.”
financing needs to be invested
each year until 2030. Technologies to Improve Production
Raw materials and the end-of-use phases The Financing the
make up around 45% of current financing
demand, according to Financing the
Transformation report
Transformation in the Fashion Industry, identified two categories of
published by Fashion for Good and Boston technological innovation
Consulting Group in 2020. 35% of financing
demand is needed to support innovation in that are the key drivers of
processing and cut-make-trim, such as transformation: “soft” and
waterless dyes and zero-waste manufacturing
infrastructure, while the last 20% is split
“hard” technology.
between retail, usage, and other innovations,
Soft technology refers to digital B2C
reads the report. Specialized funds like Textile
solutions like rental and resale platforms,

Innovation Fund and Good Fashion Fund are

as well as B2B solutions like traceability
software. Hard tech, on the other hand, is
For many investors, the “asset-intensive, physical, science-based
sustainability element in itself is technology,” which includes innovations that
not a major driver, but many integrate into existing production systems —
traceability/transparency innovators such as bio-based dyes and toxic-chemical
free solvents — and innovations that require
are able to combine positive impact
the development of new infrastructure, like
with attractive business
chemical recycling, biodegradable yarns,
models, and therefore financial and lab-grown materials.
returns, for investors. Hard tech solutions often occur deeper
in a brand’s supply chain in facilities that
Rogier van Mazijk they don’t own. Therefore, facilities are
Fashion for Good expected to improve infrastructure to be
more sustainable, but aren’t provided with
the financial support to do so. “Hard tech
has a number of fundamental properties that
working to accelerate investment in may make it unattractive to investors,” says
sustainable fashion innovation. “Brands and van Mazijk. “But part of the problem is also
manufacturers have historically not been active that investors have traditionally focused on
in providing financing for the kinds of software and therefore there are fewer
sustainable disruptive innovation similar to investors familiar with, and active in,
those that we support at Fashion for Good,” the hard-tech space.”
Supplier Investment & Collaboration 37

The Supplier Perspective

What are suppliers asking for?
It is critically important that in the industry as to whose responsibility it is
to fund sustainable transformation in facilities
investment in sustainability is that aren’t owned by brands. Generally, fashion
used to improve the working companies believe that facilities should
finance their own improvements; however,
conditions and infrastructure in the tight margins imposed by these brands
facilities throughout the entire don’t give facilities enough financial capacity
supply chain. to do so. The inability to find common ground
on this core issue creates a stalemate and
Too often, investment initiatives focus on stalls progress, which can only be resolved
retail spaces and brand-owned facilities, through open discussion and collaboration
failing to reach the facilities deeper in the about the challenges in the brand-supplier
supply chain. There is a difference of opinion relationships.
Supplier Investment & Collaboration 38

A GOTS certified tier 1 supplier in

Southern India told TrusTrace:

“Usually, textile manufacturers reside in In order to have any room to invest in

developing countries. Sustainability is improvements, supplier compensation
still not a burning issue in countries like must take into account the inflation in
ours, where the majority of the raw materials, petrol, shipping and
population is looking to just make ends increasing wages, as well as the cost 

meet. When we start our businesses, our of capital tied up from what the supplier
top priority is to provide a good life for pays for raw materials ahead of
our families and ensure our employees production. Often, suppliers receive
are able to meet their needs. In a payment 60 days after their customer
situation like this, even if sustainability has received the shipment. If customers
in terms of practice and sourcing can 
 are willing to pay more for sustainable
be appreciated, it can most certainly 
 products, brands can easily afford to 

not be afforded. Initially, these practices pay more to the suppliers as well.

are driven by brand requirements rather

than personal preferences. But after Consumers ought to know that some of
suppliers reach a point of establishment, their favorite ‘sustainable’ brands have
they can appreciate and practice these 
 even canceled orders after suppliers have
on their own, even without push 
 invested money, time and effort into
from brands.
executing them during Covid. Though
this was not the case with our brands, 

Despite sustainability being preached 
 we do know of fellow suppliers who have
in today's world, it is still suppliers that lost a fortune like this. Also, suppliers get
bear the costs of sustainable textile paid two months after delivering goods
production. Suppliers are expected to and if there are any delays, the brunt is
follow sustainable practices, source from always borne by suppliers. Consumers
sustainable suppliers, be certified under should be as eager to understand 

different material and social brand sourcing practices as they are 

certifications and yet, final product 
 to understand supplier sustainability
costs are still kept low.
practices. This will help brands stay
accountable for sourcing practices 

The least that brands can do to help and make sustainability more of 

suppliers switch to more sustainable a two-way street!”
practices is to pay the real cost of 

the goods.

The supplier prefers to stay

anonymous to avoid potentially
damaging relationships with 

their brand customers.
Case study: shimmy 39

Case Study: Shimmy

Shimmy Technologies is an AI-powered app-based training
platform designed to upskill and reskill garment manufacturing
workers anywhere. It supports efficiency, spikes in demand, and
“Industry 4.0” — what Shimmy calls the empowered collaboration
between human and machine.

Shimmy founder Sarah Krasley believes that to to address the skills and wages gap between male
acknowledge the transformative potential of the and female workers and to support womens’
circular economy, it is necessary to design positive promotion beyond entry-level positions. Shimmy is
social outcomes to support workers. Thus, also working with other major brands and retailers
Shimmy was born. such as Zalando and Under Armour.
Automation is an inevitable reality. In 2018, “Upskilling leads to workers’ resilience and
McKinsey surveyed US apparel executives and flexibility. Whilst some manufacturers are hesitant
international procurement officers who projected to upskill workers for fear they may go to a
that simple garment production will be fully different factory, more strategic ones view
automated by 2025, resulting in an 80% reduction upskilling as an investment that will ultimately
in the labor force. This leaves little time to reduce operational costs,” says Krasley.
transition tens of millions of workers (a majority of Investment in upskilling allows workers to
whom are women) to new ways of making a living.
understand critical processes and machines,
Upskilling can be thought of as a layer that runs enabling greater efficiency.

alongside the automation process. As workers are Krasley says this type of flexibility is important
displaced or reskilled into other jobs, it is brands' for a number of reasons. “If a worker needs to
and manufacturers’ responsibility to support migrate home, they can. If facilities must close
workers as the number of human product jobs because of infection, workers have the option to
become fewer and fewer.
take up work elsewhere as they are empowered
Krasley and her team are constantly tracking with diversified skills that can be deployed on
machine competencies and skills in the market to many different machines. With the impact of the
guarantee their training is calibrated with market climate crisis, one must consider the increased
needs. Shimmy first collaborated with the probability of damaging waves of infections.
International Labour Organization’s (ILO) Better Upskilling removes these bottlenecks.”

Work Programme in 2020 to research the rate of Ultimately, the reality of the transition to a
automation in the garment sector and the circular economy is that it will occur alongside
workforce impacts that will result in the country, intensified precarity and economic inequality
especially on women.
throughout the global fashion system, agitated by
The findings suggested that enhanced the impacts of the climate crisis. Krasley believes
automation won’t completely change the factory more support could be implemented in the form
set-up as traditional methods and the human of taxes and/or rebates. For example, alongside
touch are still required, making the automation of the purchase of automated equipment, a re-
the garment industry slower than in others. The skilling rebate could be included and funded in
process is gradual but early investment is key. part by local governments. Supply chain actors
Shimmy, alongside CARE Bangladesh and The cannot automate parts of the production process
Asia Foundation, recently completed a technical and leave workers to figure it out — upskilling
skills training for female workers called the Gender and re-skilling must run in tandem with any
Norms Pilot in The Future of Work project. It was updates made.
funded by the H&M Foundation, with the aim

Fashion Revolution Case Study For more recommendations on what actions can be taken to center
workers in the transition to a circular fashion system, check out this
BSR report.
The Business
Drivers of
Traceability
Laws and Regulations 41

Laws and Regulations

Legislation is coming for the fashion industry. In 2022 alone,
several new regulations and directives have been introduced,
predominantly in the EU, to define parameters around marketing
and labeling, due diligence and traceability, as well as
sustainability reporting.
Brands are facing increasing pressure to While key factors like the legal interpretation and
comply with a range of overlapping laws that practical implementation of these laws are yet to
differ from country to country, and even state be fully understood, Carriere-Pradal believes that
to state in key markets like the U.S. businesses should begin to invest in and prepare
But what do they have in common? for compliance. “Many brands still have the
“All of the regulations have embedded a same system of sustainability or the same staff
budgets that they had years ago, in an industry
requirement to strengthen traceability,” says
where the requirements of the sustainability
Baptiste Carriere-Pradal, chair of Policy Hub,
department have changed dramatically,” he
a group that represents the voices of the
says. “But the budgets haven't followed, the
apparel and footwear industry to propose capacities of the team haven't followed, and
policies that accelerate circular and they keep having to prioritize between knowing
sustainable practices.
the environmental footprint of a product or
“They ask you to know your risk all tackling forced labor in the cotton field.”
across your value chain. Normally when a Carriere-Pradal says that while many
brand thinks about traceability, they think regulations come into effect in 2026, brands
about traceability upstream. They don't think must use this time wisely to prepare their
of traceability downstream," says Carriere- business. “When you are a sizable organization,
Pradal. "What we see is that traceability 2026 may as well be tomorrow. It requires a clear
requirements will also be downstream, plan about increasing your capacity, your
meaning that if you put a product on the infrastructures and your team. It's paramount for
market that ends up on the landfill in South organizations to have a clear and ambitious target
America or Africa, it could also be your with a clear expansion of their capacity to be able
responsibility.”
to tackle those emerging demands by 2026.”
In the past, the industry’s preference
for voluntary commitments has failed to Traceability is only here to serve 

make a meaningful impact, so while it may a purpose: to enable a better
appear that many new pieces of regulation understanding of the environmental
are emerging all at once, the industry is and social risk and performance
actually playing catch-up to other highly- across your downstream and upstream
regulated sectors like the automotive operations. This requires capacity that
industry. “Some individual brands were you need to plan and budget for today.
moving forward fast, but as a whole, we It’s not just an intern that you hire for
didn't move as we should have moved, and the summer, it’s a robust team with the
everybody recognizes that,” says Carriere- means to achieve their goals.

Pradal. “That being said, there is a need for

regulation, because regulation tends to set
Baptiste Carriere-Pradal
clear targets, which will be key to move Policy Hub
forward. This will require a lot of time and
some predictability to be deployed at scale."
Laws and Regulations 42

Key Laws and Regulations

It can seem like a daunting task to Ensure that consumers are provided with
keep track of, let alone comply information at the point of sale about a
commercial guarantee of durability as well as
with all the global laws and information relevant to repair, including a
regulations out there. repairability score, whenever this is available
Extended Producer Responsibility and
Detailing all of them would fill a book, so we’re boosting reuse and recycling of textile waste
looking into some of the laws that are affecting
sustainability within fashion right now:

In 2020, the European Commission issued a

the European Green Deal and the Sustainable
new legislative proposal: the Substantiate Green
Textile Strategy, the Uyghur Forced Labor
Claims Initiative.
Prevention Act, The New York State Fashion 

Act, and the FABRIC Act. We will also share a It may require companies to substantiate any
broader overview of the types of laws and impact-related claim with a standard methodology
regulations affecting the fashion industry and (PEF will very likely be selected). The objective of
when they are expected to come into force. this initiative is to move to a more harmonized
approach for providing reliable environmental
information. All options will cover claims made for
The European Green Deal any of the 16 environmental impacts covered.
Options will be considered in synergy with the
The European Green Deal, published in 2019,
other initiatives announced in the CEAP.
states that, “Companies making ‘green claims’
should substantiate these against a standard
methodology to assess their impact on the
environment. The Anti-Waste for a Circular
Via the Circular Economy Action Plan (CEAP) Economy Law
in 2020, the European Commission announced
a legislative proposal to require environmental In May 2022, France introduced a new
claims to be substantiated using the Product decree as part of the Anti-Waste for a
& Organisation Environmental Footprint (PEF & Circular Economy (AGEC) law, which
OEF) methods. In March 2022, the textile focuses on consumer information about the
industry was called out as a key focus area, environmental qualities and characteristics
addressed by the EU Strategy for Sustainable of waste-generating products. The aim is 

and Circular Textiles, which is why the European to inform the consumer on the conditions
Green Deal is now pivotal to consider and plan relating to better prevention and gestation
for going forward. The Sustainable Textile of waste.
Strategy covers both Extended Producer The decree mandates distributors,
Responsibility for products beyond the point importers, and producers to disclose more
of purchase, all the way to end of life, as well as detailed information about their products.
the empowerment of consumers to make better Specifically, they will have to disclose
choices. This includes: information on traceability and the country
where each of their processes such as
Introducing mandatory ecodesign weaving, dying, and tailoring is performed.
requirement They will also need to provide granular data
Stopping the destruction of unsold or on the recyclability, the recycled material
returned textile content, and the presence of harmful
substances in their products.
Addressing microplastics waste The time frame is quite ambitious and
Introduction of a digital product passport to will be applicable from January 2023.
provide clear information on environmental
characteristics of a product
Laws and Regulations 43

Diagram on EU Legislations

EU Green Deal

CEAP (Circular Economy Action Plan)

Communications: Inform about
the orientation of EU legislation
Sustainable
and the articulation between the
Textile Strategy EPR for
Amends Waste

Framework
 different laws.
Textiles (2023) Directive

Sustainable
 Revises and Repeals Ecodesign


Products Initiative Directive
Existing EU laws: In force
Developed in close coordination
today, passed several years ago.
Substantiating
 Empowering
 Amends Unfair

Consumers in
 Commercial

Green Claims Green Transition Practices Directive
Defines the

scope of
Corporate

utilization Sustainability
 New EU texts: New
Corporate
 Reporting Directive legislative initiatives, that
PEF Method

(Product Environmental
 Sustainability Due
Non Financial
 are not yet laws. Initiatives
Footprint) Diligence Directive Amends Reporting Directive that will trigger a transition
in the textile industry.

The Uyghur Forced Labor Prevention Act

The Uyghur Forced Labor Prevention Act. In until importers can prove that forced labor has
late 2019, numerous investigations into the not been exploited in the supply chain. In order
detention of Uyghur Muslims in the Xinjiang to prove this, importers must:
Uyghur Autonomous Region (XUAR) of China
revealed that fashion’s supply chains were Provide a certificate of origin, signed by
complicit in the forced labor of at least the seller/manufacturer/owner of the
80,000 Uyghur people between 2017-2019. article (19 C.F.R §12.43 (a);) a standard
As 84% of China’s cotton exports come from certificate of origin is not acceptable
this region — making up 1 in 5 cotton garments
on the global market — many of fashion’s Accompany the import with a detailed
biggest brands were found to have acquired statement which discloses the ultimate
cotton linked to forced Uyghur labor. consignee of the merchandise and the
In response, the US Customs and Border merchandise’s entire supply chain, from bale
Protection (CBP) issued a withhold release to final product, including names, production
order (WRO) in 2021 against cotton and cotton process and addresses of each supplier.
products produced in whole or in part in the
XUAR. Expanding on the scope of the WRO, Failure to comply will result in fines of up to
the Uyghur Forced Labor Prevention Act will $250,000, or twice the amount of the transaction
come into effect in June 2022. It decrees that being held by the CBP. Click here for more
all products coming from the XUAR, not just information on The Uyghur Forced Labor
cotton, will be prevented from entering the U.S. Prevention Act.
Laws and Regulations 44

New York State Fashion actions to ensure environmental and

social issues are identified and prevented,

Sustainability and Social including a liability clause that holds brands
Accountability Act accountable for wage theft in their supply
chain, in line with the California Garment
Introduced in January 2022, this bill is Worker Protection Act (SB62).
commonly referred to as the Fashion Alongside this, the proposal of the
Sustainability Act. This proposal holds fashion Fashioning Accountability and Building Real
brands with over $100 million in revenue that
Institutional Change (FABRIC Act) is calling for
sell within the state of New York accountable for the following federal level regulations in the U.S.
their environmental and social impact. New York
is the epicenter of American fashion, so this bill The establishment of a $40 million Domestic
could impact the biggest brands in the world Garment Manufacturing Support Program to
and set a precedent that other fashion capitals supply grants to manufacturers for
may follow.
 equipment costs, safety improvements,
If it becomes law, affected brands will be training and workforce development
required to map at least 50% of their suppliers
by volume across all tiers of their supply chain A 30% reshoring tax credit for garment
in order to identify the high-risk players. manufacturers who move manufacturing
Businesses will then set and disclose annual operations to the U.S. This credit will be
carbon emission reduction targets, material applicable to costs associated with reshoring
production volumes, breakdown by material production
type, as well as the percentage of their raw
materials replaced by recycled material. The establishment of a nationwide garment
Because transparency is at the core of this bill, industry registry through the Department of
businesses must produce and publish an annual Labor to promote transparency, hold bad
report on their progress. Failure to comply may actors accountable, and level the playing
result in fines of up to 2% of annual revenues, field
which will go into a Community Benefit Fund for
environmental projects. As of May 2022, the bill New requirements which hold fashion brands
has stalled and its future is uncertain. and retailers alongside manufacturing
partners jointly accountable for workplace
Click here for more information on the Fashion wage violations to incentivize fair
Sustainability Act. workplaces, starting at the top

Setting hourly pay in the garment industry

The FABRIC Act and eliminating piece rate pay until the
minimum wage is met to ensure jobs with
In an effort to strengthen the Fashion dignity. Productivity incentives on top remain
Sustainability Act, Remake, alongside Fashion protected.
Revolution and 18 other organizations, sent a
letter to the Fashion Sustainability and Social
Accountability Act to elected officials following Click here for more information on the
its publication. The bill proposes more concrete FABRIC Act.
Laws and Regulations 45

The laws and regulations timeline

Below, we have outlined some of the laws and likely to change, but what will not change is that
regulations affecting the fashion industry and laws and regulation are here to stay. To get a
when they are expected to come into force. better sense of the different laws & regulations,
Some of them are a couple of years away, you can look at them as belonging to one of the
meaning that the exact time of enforcement is five groups:

Due Diligence & Laws that require companies to identify and mitigate environmental and/or social risks along
Traceability their supply chain. To do so, companies need to start by mapping their suppliers.

Laws that require brands to collect certain information about the supply chain at a product
Product

level. It can be country of origin, environmental negative impacts or social negative impacts.
Traceability
This requires to build a product tree identifying all suppliers involved in the making of a specific
product.

Laws that require companies to disclose sustainability related information in their financial
Sustainability
reporting. It often has two dimensions: the impact of the company and its activities on
Reporting
ecosystems and people and how sustainability issues affect a business. It requires advanced
knowledge of the supply chain.

Claims
Laws that require companies to substantiate any environmental or social claims made with
reliable and relevant evidence. If companies want to make marketing claims related to the
Substantiatio n
material composition of their products, they need to establish a proper material traceability
system.

Advanced Consumer
Laws that require companies to label their products with very detailed sustainability
(
information. The requirements can be around environmental scoring with a calculation
Information ) ( ) (
methodology , circularity recyclability, recycled content , traceability country of the different
) (
manufacturing processes and other sustainability information harmful substances,
)
microplastics release . These laws require gathering very granular data about the product life
cycle, for which product traceability will be a minimum requirement.

Due Diligence & Traceability and Product Claims Substantiation requirements during 2024. 

Traceabilty requirements will come into effect first. On the following page, you will find an overview
These are followed by Advanced Consumer of the different groups of legislation, what
Information Requirements for companies selling countries they are made in and relevant to, 

in France, expected in early 2023, Sustainability and the specific laws included in the overview.
Reporting requirements in late 2023 and the

 Laws and Regulations 46

9 10 11
Granularity of required data

Advanced Consumer Information requirements

8

Claims Substantiation requirements

6 7

Sustainability Reporting requirements

5

Product Traceability requirements

1 2 3 4

Due Diligence & Traceability requirements

2022 2023 2024 2025 2026 2027 2028 2029 2030

How to read the graph

The colored stripes represent different types of requirements. Their position on the
graph signpost when the first requirements of this type are expected to be mandatory.

More detail is brought by the geographic bubbles placed along these stripes. 

Each bubble represents a legal text, it can either be a law that has been adopted or a
legislative proposal that had not been adopted yet. Their position signifies when their
first requirements are supposed to be applied (not their publication date).

The bubbles that are made of one flag mean that the law represented applies 

to companies based in the country designated by that flag. (Sometimes, local
subsidiaries of foreign companies can also be included).

The bubbles that show the world + a flag mean that the law represented applies to
companies selling goods or services in the country/region designated by the lag,
regardless of where they are based. For example:

US Companies
Companies doing business in
are concerned by the act the US are concerned by the act

The below laws are the ones covered in the graph:

1 – Dutch Child Labor Due Diligence Act: This Act is a Child Labor Due Diligence Act. It was adopted in 2019 and is supposed to be enforced mid-2022. ​

2 – Norway Transparency Act: This Act is a Human Rights Due Diligence Act. It was adopted in 2021 and will come into force from July 2022.

3 – German Supply Chain Due Diligence Act: This is both a Social and Environmental Due Diligence Act. It was adopted in 2021 and the first requirements will be enforced in 2023. ​

4 – EU Corporate Sustainability Due Diligence Directive Proposal: (Also known as Sustainable Corporate Governance Initiative); This proposal is both a Social and Environmental Due
Diligence Act. It aims to harmonize all the Due Diligence requirements at EU level. The proposal was published in 2022 and we can expect it to be in force around 2025. It needs a delay to
be adopted and then to be transposed in the Member States’ law (as it is a Directive). ​

5 – US Uyghur Forced Labor Prevention Act: This Act is a Withhold Release Order issued by the US Customs and Border Protection. The Customs will withhold all cotton products
suspected of having been manufactured in whole or in part in the Xinjiang Uyghur Autonomous Region. The Act was adopted in 2021 and will enter into force in June 2022. ​

6 – EU Corporate Sustainability Reporting Directive Proposal: This proposal standardizes requirements for sustainability reporting. Companies will have to report both on their impact
on people and the environment and on how these issues affect their activities, strategy and positioning. The proposal was published in 2021 and we expect its requirements to apply from
the 2024 reporting (for 2023 fiscal years) as is stated in the proposal. ​

7 – US SEC Proposal for Climate Related Disclosure Rules: This proposal defines sustainability reporting requirements for listed US companies. The requirements are similar to the EU
CSRD (6) but companies will have to include their GHG emissions in the section about their impact on the environment. The proposal was published in 2022 but we can expect the first
requirements to apply in 2024 for the 2023 fiscal year as stated in the proposal. ​

8 – EU Empowering Consumers in the Green Transition Directive Proposal: This proposal aims to tackle unfair and misleading social and environmental claims. In other words, it aims
to prohibit ”greenwashing”. The proposal was published in 2022 and we can expect the first requirements to be applied between 2024 and 2025. ​

9 – French AGEC Law: This law adopted in 2020 amended the French environmental code with an article that will require companies putting waste-generating products (including textiles)
on the French market to inform consumers about the environmental characteristics of products. An implementation decree published in 2022 sets the enforcement date of the first
requirements in January 2023 (for companies with the highest turnover in France for such products). ​

10 – French Climate & Resilience Law: This law contains one chapter with the aim to make environmental scoring mandatory for some categories of products. Textile is identified as one
of the priorities. It was adopted in 2021 but we can expect its first requirements to be binding around 2025-2026 as the scoring methodology and the database are yet to be defined. ​

11 – EU Ecodesign Requirements for Sustainable Products Regulation Proposal: This proposal will define a series of ecodesign and information (Digital Product Passport)
requirements for different categories of products. Again, textile is a priority sector. Depending on what will be stated in the implementation acts, the information requirements (DPP) for
textiles can be very granular. The proposal does not include environmental scoring requirements yet, but we expect a similar obligation to be included in information requirements in the
years to come. The main regulation will probably be adopted around 2024, then separate acts will be published tackling different product categories. This leads us to expect environmental
labeling requirements for textile around 2027.

Please note, the New York State Fashion Act and the FABRIC ACT are not included in the overview, as it is still unclear if and when they will come into force.

To learn more about these and other laws in greater detail, visit the TrusTrace Knowledge Hub.
Transparency and Communication 47

Transparency and Communication

Communicating product-specific brands to align their marketing claims with.

impact data to consumers is no In order to comply with laws, claims must be

truthful and accurate, clear and unambiguous,
mean feat — even the biggest must not omit or hide important information,
brands in the world struggle to
must only make fair and meaningful
get it right. This is because brands comparisons, must consider the full life cycle

of the product, and must be substantiated.

are attempting to condense and
simplify incredibly complex
Fashion Revolution’s Tips to
information, and lots of it.
Comply with Greenwashing Laws
In 2021, the UK’s Competition and Markets
Authority (CMA) found that 40% of 500 Audit existing claims. When making a
consumer goods brands were making claim like “carbon neutral”, it is vital that
misleading claims about their sustainability brands substantiate this with audits and
credentials online. A 2022 survey of executives make information on their time-bound and
across different industries, which was measurable targets and progress publicly
conducted by the Harris Poll for Google Cloud, available. Brands should review their
found that “58% agree that green hypocrisy marketing communications against the
exists and their organization has overstated their CMA’s Green Claims Code to see if it could
sustainability efforts.” It’s easy to see why 62% stand up to the scrutiny of the public
of consumers distrust sustainability information
provided by brands, according to a 2021 survey Make information more accessible.
from Changing Markets.
It is impossible to communicate all the
information related to the sustainability of
a specific item, which is why QR codes are
Greenwashing a great way to connect consumers with
Greenwashing is rife in fashion, and it’s
the information to support claims
setting the sustainability movement backwards.
“I believe greenwashing has been in existence Integrity. Brands and retailers must be
as long as the compliance industry has,” says prepared to take responsibility for any
Maeve Galvin from Fashion Revolution. misleading claims but they should not be
“Fundamentally, there is significant market value making them to begin with. Brands should
in ‘guilt-free’ shopping and greenwashing is a not be reserving compliance for when they
means for brands to satiate consumers that their are scrutinized and held accountable legally.
products are the exception rather than the rule. To better facilitate this, there needs to be
Greenwashing feeds directly into the enormous
better communication internally as
need many mainstream consumers have to be
oftentimes, product design, marketing
told ‘where’ to shop, as if it resolves the
and sustainability teams work in silos. It is
problem.” Following its latest global review, the
CMA released the Green Claims Code in 2021 to important that teams are transparent and
combat greenwashing with six aligned with their communications and the
recommendations for information needed to substantiate claims.

Transparency and Communication 48

Information Dumping 10% of brands publish time-bound,

measurable commitment to zero
Another barrier preventing consumers from deforestation
understanding the green claims of a brand is

the practice of information dumping. This can 27% of brands disclose their approach to
happen when brands don’t know what achieving living wages for supply chain
information is relevant and interesting to
workers. Only 6% publish annual progress
their consumers, so they share everything. towards paying living wages and 1% publish
“Some big brands communicate their human the number of workers being paid a living wage
rights and environmental efforts in a way that
25% of brands publish measurable, time-bound
is overwhelming, impenetrable, repetitive and targets for the reduction of textiles deriving from
difficult to find, making it virtually impossible for virgin fossil fuels and 18% of brands publish
their customers and stakeholders to decipher annual progress to achieve this.
information that is meaningful and actionable,”
reported the 2021 FTI. “When communicating product impact with
“Sometimes crucial pieces of data are hidden consumers, it’s important to ensure that your
in annexes and footnotes of long technical marketing efforts are authentic, transparent and
reports or buried dozens of clicks away from the relatable,” says Akhil Sivanandan, co-founder, co-
homepage of their website. At other times, there CEO, and CCO of Green Story, a Dutch company
is so much information to read through…that it that conducts Life Cycle Assessments and
almost seems like a deliberate strategy to communicates product impact for brands like
obscure and distract,” reads the report. Whether Esprit, ThredUp, and PANGAIA.

intentional or accidental, information dumping “Making fair and meaningful comparisons

occurs when brands are unable to communicate when communicating a product’s environmental
in a clear, accessible manner that educates performance is useful information for consumers,”
curious consumers, rather than confusing them. says Sivanandan. “When communicating your
product comparisons, be sure to make this fair
and outline what exactly you are saying has a
Communicating Product- better impact, as well as providing data to support
Specific Impact Data this, in order to avoid accusations of
greenwashing.” Green Story communicates
Before you communicate product impact data, product impact with equivalences (X product’s
you have to measure it. Across the industry, the positive impact is equal to Xkms of driving
adoption of measurement tools is still relatively emissions avoided) and actuals (X product’s
low, therefore reporting on specific product positive impact is Xkgs of CO2e avoided), to
impact data is scarce. connect with consumers in accessible but
According to the 2021 FTI, of the 250 brands accurate terms.
reviewed
3% of brands disclose the percentage of When it comes to sustainability
products that are designed to enable closed- claims, brands not only must be able
loop or textile to textile recycling at end of life to respond to consumers’ doubts, but
also be mindful of upcoming green
62% of brands publish their carbon footprint legislations.
for their own operations and facilities.
Akhil Sivanandan
31% of brands publish annual water footprint Green Story
in owned and operated facilities. This drops to
14% at the manufacturing/processing facility
level and 5% at the raw material level. 

Sustainability Beyond the Corporate Level 49

Sustainability Beyond the Corporate Level

Sustainability policies and emissions. In 2016, 92% of Fortune 500
companies used The Corporate Accounting and
initiatives have been commonplace Reporting Standard (Corporate Standard) from
for the last decade, but have failed the GHG Protocol to calculate their Scope 1

to make any tangible dent in the and 2 emissions. The GHG Protocol has also
published Scope 3 Calculation Guidance in
industry’s environmental and partnership with the Carbon Trust, which they
social impact. say is “the only internationally accepted method
for companies to account for these types of
This is because true sustainability goes beyond value chain emissions.”
corporate social responsibility and touches every
part of the supply chain, down to the fiber level.
“When it comes to beyond tier one of the supply
Internal Drive
chain, traceability can prove challenging,” says A 2020 census from Unily of 2,000 UK workers
Galvin from Fashion Revolution. “However, this is reported that 65% of respondents wanted to
precisely why we believe that brands need to work for a company with a strong environmental
look beyond their own singular supply chain and policy, however, 83% believed their employers
examine the wider system their product is a part weren’t doing enough to fight climate change.
of. Investing in direct relationships can help As environmentally conscious Millennials and
traceability where existing technology lacks.” Generation Z begin to dominate the workforce,
it’s important that businesses align with their
values and expectations in order to attract and
Calculating Business Emissions retain talent.
The 2021 FTI reported a 4% year-on-year
increase in brands disclosing the annual carbon External Pressure
footprint of their own facilities and operations In recent years, sustainability has become

(known as Scope 1 and 2); however, up to 80% an increasingly important consideration for
of the sector’s carbon footprint occurs in Scope consumers. 63% of shoppers have made
3, where the raw material sourcing, processing, “modest to significant shifts towards being more
and assembly occurs. sustainable in the past five years,” according to
By failing to account for Scope 3 emissions a 2021 Global Sustainability Study by Simon
in carbon footprint analysis, brands aren’t giving Kucher & Partners. This is driven by Millennials,
the full picture of their environmental impact. In 32% of which have made significant lifestyle
April 2022, the Guardian revealed that brands changes to be more environmentally conscious.

that work with the CDP (formerly known as the In 2021, IBM found that the pandemic had
Carbon Disclosure Project), an independent a significant impact on 9 in 10 consumers'
environmental performance organization, views of environmental sustainability — even
were calculating carbon emissions against more so than natural disasters. 34% of those
total revenue. “This means that as long as surveyed by Simon-Kucher & Partners were
their emissions increase less than their revenue also willing to pay more for eco-friendly
increases each year, the total emissions are products, further proving that investment
scored as a decrease,” wrote journalist Rachel in sustainability is good for business.

Donald.
Organizations like Fashion Revolution
Calculating Scope 3 emissions is clearly a have also been instrumental in pressuring
huge challenge for brands, one that revolves legislators and brands. “As activists, we need
around procuring large amounts of data from to convince consumers that the problem can
their suppliers. A leading body in helping brands only truly be resolved by transforming our
understand how to track their emissions is the entire relationship with clothing consumption
Greenhouse Gas Protocol, which sets the and ultimately the functioning of the entire
standards by which brands can measure their fashion industry,” says Galvin.
A call for collaboration 50

A Call for Collaboration

The challenges facing the fashion
industry cannot be tackled alone. revolutionizing the industry. Digitizing,
democratizing and standardizing data should
Industry-wide collaboration, not be the top priority of fashion brands, retailers,
competition, is vital to achieving suppliers, and factories. In the next section,
wide-scale improvements. you’ll learn how to identify where your business
currently stands in relation to traceability. By
“The potential of more collaboration where situating your business within the TrusTrace
brands use their shared economic power for Levels of Traceability, you can understand how
greater impact is vast,” says Galvin. She points to best leverage traceability to accelerate your
to policy-making in production countries, journey towards sustainable transformation.

supporting joint price negotiations for better

wages, or shared investment in greener
technologies to support the transition from Real collaboration has
fossil fuels, as areas that brands could practical and economic value,
collectively influence include policy-making as well as the potential for
in production countries. “We advocate brands major impact.
sharing resources and collaborating to
converge standards and reduce the burden on
suppliers as much as possible," says Galvin. Maeve Galvin
With so many players in this dynamic Fashion Revolution
ecosystem, from farms to factories and beyond,
accurate and granular data is the key to
Within TrusTrace’s
Three Levels of
Traceability
The Three Levels of Traceability 52

The Three Levels of Traceability

We’ve covered the fundamentals of traceability, now we’re
ready to dive into how you can actually achieve it. In this
section, you’ll learn about how traceability can help you to
achieve your sustainability goals by understanding the different
methods for tracing your supply chain.

Every fashion business will have a unique from the factory that supplied trimmings to the
traceability journey, as each has its own specific farm that grew the raw materials. Envisioning
ambitions and commitments. What’s right for this journey as a series of levels can help us to
your business will depend on where you are in understand that traceability is about a step-by-
your sustainability journey already — some step progression towards sustainable
of the deeper levels of traceability require a transformation.
certain degree of maturity and readiness. We separate traceability into three distinct
We understand that beginning this journey but interconnected segments: the supplier,
can be a daunting task, so this guide is here product, and material levels. In this chapter,
to demystify and simplify the process. we’ll unpack what you can expect and achieve
The TrusTrace Levels of Traceability have from each level. Additionally, you’ll be able to
been devised using the knowledge and insight understand the difference between manual and
we have gained since we began supporting digital traceability solutions, learn more about
fashion businesses through their sustainability Chain of Custody methods, as well as the
transformations in 2016. Consider this your benefits and challenges of product backward
guide to evaluating the traceability solutions that (top-down) and fiber forward (bottom-up)
are right for you.
solutions for achieving traceability. In short,
Each level of traceability takes you a little you’ll be able to identify the levels and
deeper into the supply chain of your products, methodology that are right for you.
Manual vs. Digital Traceability 53

Manual vs. Digital Traceability

Manual Traceability
Most brands start out their traceability journey this data is consolidated and made available for
with what we call manual systems, achieved by all functions to see, making it much easier for
sending emails and collecting data in Excel sourcing, production, legal and compliance
spreadsheets. This works when a brand is teams to collaborate and act on the
collating general information about its suppliers, information. A lot of data that is required for
but as you scale your ambitions for system-wide traceability is currently available in PDFs (like
traceability, manual systems will prove audit certificates, transaction certificates, or
unsuitable. invoices around the chain of custody) so
For example, if working with certified digitizing this information is one of the first
materials, a large fashion brand can process steps in the traceability journey. When a social
500,000 certificates between certified tier 1 audit certificate is digitized, brands can easily
suppliers to the final product purchase order keep track of the certificate’s validity, as well as
each year. We calculate that it would take one which of their supplier facilities are covered by
person 19 years, or 41,667 working hours, to it. Major issues that conflict with the brand’s
complete this task manually. Manual systems goals can be tracked and analyzed so that
also result in fragmented data that is low on corrective action can be taken.
detail and not easily shareable across functions. As new regulations are emerging, the
Large brands will find it difficult and inefficient to need for high quality, granular data about the
communicate with and build profiles on all their materials and supply chain is ever increasing.
suppliers, as tracing beyond direct suppliers Any claim that is made on a product today
manually would become time-consuming and requires specific data to back it up. For
complex. Luckily, digital traceability provides example, a material content claim, such as the
a solution to this.
percentage of recycled polyester in a product,
will require data about the complete material
Digital Traceability chain of custody.

To implement traceability at scale for cases

Sustainability is no longer an independent like this, a digital traceability system should have
function within a fashion business. A brand’s intelligence on which product should be traced,
ability to improve the sourcing strategies aligned what data needs to be collected, and from
to their sustainability goals will be severely whom. This intelligence comes from product,
limited if they have an audit report or a scope supplier and order data that is already stored in
certificate in an email, but don’t link the expiry Product Lifecycle Management (PLM) and
details with the supplier information. This is Enterprise Resource Planning (ERP) systems,
where a digital traceability system comes into which can be integrated with a digital traceability
the picture. system, ensuring a continuous flow of up-to-
A digital traceability system helps brands date information. With this automated digital
collaborate with suppliers across tiers on a near solution, brands achieve traceability at scale and
real-time basis, so that brands and suppliers can reduce the amount of time spent collecting data,
exchange details about their supply chain, so time can instead be spent analyzing that data
products, and materials. Through the system, and developing data-led strategies.
Manual vs. Digital Traceability 54

As traceability becomes critical across materials, Benefits for Suppliers

it is imperative to replace the current paper-
based transactions, including material Avoid spending time sending and keeping
certification processes by third parties, with track of individual emails and documentation
per sub-supplie
digital ones. This requires a decentralized,
robust and secure technology like Blockchain.
Have agency over their own information,
Blockchain helps to establish the authenticity which can easily be updated and shared with
of material certifications as well as proof of multiple brands
ownership at any given point in time and is
completely tamper-proof. Through blockchain- Keep documentation up to date: digital
enabled product passports, suppliers, brands, systems automatically track and remind
consumers, certifying groups, recyclers, and suppliers to upload new certificates when old
other players in the fashion ecosystem have ones expir
access to encrypted, decentralized and
Have proven sustainability credentials, which
evidence-based information throughout the
can improve competitiveness and access to
lifecycle of a product. It is important to note,
sustainable financing opportunities
however, that blockchain in itself is not a magic
bullet, and although it enables decentralization
and collaboration around data, this will not Benefits for Brands
matter if the data in question is not granular,
Saves a LOT of tim
accurate, and up to date.
Considering that the fashion industry uses a Enables automated data collection from
vast number of materials and a highly distributed suppliers
supplier network, there won’t be a single
traceability system across the entire industry, Makes data available to everyone across
but rather an ecosystem of players that interact business function
to form different solutions pending on brand or
industry needs. For example, traceability data A single data source eliminates the need to
for different materials can be stored with validate and consolidate data across multiple
different standards bodies, in supplier systems sources and system
and traceability software systems, but to
Enables brands to make and back up
achieve industry-wide traceability and visibility,
compliance claims about their products and
all these systems must eventually be able to
material
work together. To ensure this seamless data
exchange, all traceability systems should Ensure that certificates documentation is up
adhere to standards like GS1.
to date: Automatically track and remind
The major benefit of a digital traceability suppliers to upload new certificates when old
system is that it provides a single source of ones expire, preventing frau
truth about a product across the network,
from suppliers and brands to retailers and Enables automated consolidation of delivery
consumers. It helps the entire industry to vs. PO requirement
analyze, act and improve its sustainability
efforts. Here are some specific benefits to Enables tracking and visualization of
suppliers and brands:
performance vs. targets
Level One: Supplier Mapping 55

Level One

Getting Started: 
 How?

Supplier Mapping is achieved by asking your
Supplier Mapping direct suppliers to provide information about
their suppliers, who in turn ask their suppliers for
information, and so on. You can continue on until
The Basics you reach the tier where you source your raw
materials (usually tier 4 to 6), or stop at a
Gather all your supplier information in particular tier that is relevant to your needs. How
one plac much of your supply chain you map depends on
Gain an overview of suppliers in some or a number of factors. These include the depth of
all stages of the supply chai information you need, whether your suppliers
work with certifiers and auditors, the complexity
Identify, monitor and analyze supply of your supply chain, how much time and money
chain risks across tiers to ensure you’re willing to invest, and your ability to collect
sustainability standards are me and store the information you request. It also
Keep track, send out, and collect audits requires a high level of trust and cooperation
& certification from your suppliers to provide information.

Create scorecards and perform due

The key information that is collected during
diligence and ESG reporting
Supplier Mapping includes
Suppliers and facility details across tier
Why? Social data about suppliers and facilitie
Supplier Mapping is a good starting point for
Social, environmental and material related
transparency efforts, primarily because it helps
certifications and audit report
to comply with due diligence laws around the
social and environmental impact of your supply Due diligence assessments related to the
chain. Collecting social and environmental social and environmental performance of the
evidence, and keeping this information easily suppliers
accessible, is one of the main requirements in
all due diligence laws. Brands with internal
strategies to improve sourcing and gather data
Challenges and Limitations
from suppliers in an automated manner will also Supplier Mapping will only get you so far in your
benefit from this level of traceability. sustainability journey. At this level, you will not be
able to identify the value chain of individual styles
What? or products, and you do not have the ability to
identify which suppliers you are using more than
Supplier Mapping is the first step in any others. For example, your total supplier network
business’s traceability journey as it allows you may include 1000 suppliers, but you may only be
to gain an overview of all the potential suppliers actively working with 500 of these. This means you
in your network, and document everything from aren’t able to target the parts of your supply chain
their energy use to the labor conditions in their that need immediate attention. Supplier traceability
factories. You can also record and analyze third- doesn’t provide you with a chain of custody for
party audits to understand and improve the ESG products, meaning that it’s not sufficient for all
performance of your suppliers. At this level, types of regulatory compliance.
you’re able to identify the risk areas in your We encourage brands to be ambitious and
supply chain, gather evidence to help you mitigate consider supplier mapping as the first, not the
these risks, and make claims at a corporate level only, step in your sustainability journey. While
about your supply chains. Supplier Mapping can mapping your supply chain is essential in order to
help you identify whether or not your supply move to the next level of traceability, it should be
chains are powered by renewable energy or done in conjunction with product traceability to
do not include child or slave labor. understand your supply chains on a deeper level.
Level Two: Product Traceability 56

Level Two

Building Your Understanding:

Product Traceability
The Basics You’ll be able to identify exactly what the
Understand your product journe supply chain looks like for your product,
tying all the evidence from supplier
Understand the key suppliers for
particular product mapping to the product you are tracing.
Evidence for certified materials, such as
Manage evidence and prove the transaction certificates, come with a lot

authenticity of products
of data readily available.
They follow a Chain of Custody (CoC)
Why? model documenting the origin, components,
Preparing for incoming regulations on product processes, and handlers of the materials
traceability means that you will need to collect throughout the supply chain. However, if
information on specific metrics at a product you are working with products that lack third-
level: exactly where your products have traveled, party certification or involve high-risk risk
the suppliers and manufacturing regions that supply chains where CoC has not yet been
have been involved, and the evidence to prove it. established, you can use product traceability
Product traceability helps to build granular to understand your product supply chain
information of a product’s journey which brands better, as a way to prepare for traceability
can leverage for compliance and their at the material level, through which the CoC
transparency initiatives. can be established.
Product traceability can be used to make
What? general claims about a certain product that
isn’t tied to a specific batch of production.
Product Traceability gives you a retrospective For example: It’s frequently used for making
view of how your products were realized from sustainability claims for leather products.
raw materials to finished goods, and is typically
Leather is connected to certain environmental
traced from the finished product backward.
risks such as chrome usage during the
tanning and dying processes, as well as
Product backward traceability is deforestation (specifically in the Amazon)
achieved by tracing the supply chain of a caused by cattle farming.
product after it has been manufactured. It Both of these risks can be addressed by
is suitable for making general claims providing additional evidence of chemical
about your supply chain, and for products certification, as well as a country of origin
made with materials that are considered declaration from the supplier, which will help
low-risk or are unregulated. However, brands to make claims like “Our suppliers
because the data can be documented up are certified to be chrome-free.” Product
to six months after the product arrives to Traceability is not sufficient to make specific
market, product backward traceability is claims on the product, only supply chain-
considered less reliable, as certain related claims like certifications.

assumptions and generalizations have

been made in the data gathering process.
Level Two: Product Traceability 57

How? The data usually collected through Product

Traceability includes
Product traceability is achieved through Granular bill of material information for the
the same methodology as Supplier Mapping produc
(which is a prerequisite to this level), only the
Supply chain information of a product and
data extracted is more granular, down to the materials across different tiers
product or style. You can visualize this as a
Specific declarations related to raw materials
tree of information that contains a product at or processing methods used by supplier
the top and branches that represent every
Material certificates and quality reports
supplier that has contributed to its
related to the product
production.
This tree is much smaller than the overall
supply chain map that you can achieve Challenges and Limitations
through supplier mapping, narrowing in on
specific products and their associated Like Supplier Mapping, Product Traceability only
suppliers. When done manually, Product gives you part of the picture, as it does not tell
you details about the content of your products,
Traceability is challenging to achieve beyond
not does it collect data in real-time, meaning the
tier 2 and can become a time-consuming task
evidence is often not available until several
(depending on the breadth of products being months after the product is finished. It is
traced) that requires cooperation from your insufficient to make material-based claims or
direct suppliers. When done digitally, product provide you with weight-based calculations on
traceability is much more easily scaled your product material compositions, especially
beyond your direct suppliers through when there is no third-party certification
automated evidence requests. available for the material.
Level Three: Material Traceability 58

Level Three
If your business has made commitments to
Compliance Ready: 
 science-based targets, such as switching to
100% recycled polyester or increasing the
Material Traceability number of sustainable materials used across
your product offering, you will need to achieve
Material Traceability. Compliance is a major
The Basics driver in embracing Material Traceability,
because it gives you the ability to prove material
Substantiate claims about the material
claims and comply with regulatory requirements.

composition in your produc

Verify the weight-based material composition Fiber forward traceability refers to tracing a
of your product product from the raw material to the final
product. As the material Lot moves up the
Understand the waste that occurs in your value chain, each handler is proactively
production
recording critical details about the Lot and its
Verify that you received what you ordered and associated claims. These details are passed
that the items deliver on the Bill of Material onto the next tier, forming a chain of custody.
(BoM) from the product Purchase Order (PO) As the data is registered when the movement
of materials happens, it is more accurate and
verified than the retrospective data of product
Why? traceability, and it is readily available together
While brands are transforming their sourcing with the final product. Any external
strategies to include more sustainably produced disruptions or changes to the suppliers and
materials and making claims about it to the materials will be registered in real-time and
market, there is still a significant gap in backing brands can act before the product reaches
up these efforts with data. Currently, brands rely them. Fiber forward traceability is especially
on standards and certification bodies, but not suitable for multi-component products, such
all materials are covered by standards and as trainers, which could otherwise be
certificates. Because a large number of suppliers cumbersome to trace backward from the
have not yet adopted them, the certificate chain finished good.
is not always present until the finished product.
Material traceability helps solve this challenge by
providing direct control of the materials that are
sourced and building a CoC that provides
u
Chain of C stody Models
assurance for the claims you are making. To implement Fiber forward traceability, brands
should choose the right Chain of Custody model
based on the specificity of the claim being made.

What?
Material Traceability goes beyond basic
C C
A simple definition of hain of ustody is
supplier or product traceability and is
the chronological record of a product s ’
origin, components, processes and handlers
concerned with the contents of your products,
throughout its lifecycle.
diving deep into your supply chains where raw
materials are sourced. It’s based on the Fiber
forward model which means that you’re able
In fashion supply chains, Product Segregation
to make claims about the specific material and Mass Balance are two frequently used
content on a product by product basis,
Chain of Custody models. Product segregation
with the chain of custody to prove it. means that the certified raw material is physically
Level Three: Material Traceability 59

separated from non-certified materials Challenges and Limitations

throughout the whole supply chain, which makes
this a more accurate approach than Mass As Material Traceability requires collaboration
Balance, where the certified and non-certified with suppliers to document the materials going
materials can be mixed along the supply chain. into the manufacturing process of a product,
Even though Product Segregation is the more brands need to have a direct relationship and
accurate option, Mass Balance is less complex ability to communicate with their suppliers
to implement, and brands might choose to use through all the tiers they want to trace. If a brand
both models, depending on their ambitions. For is one out of many customers of a supplier, it
more specific product claims such as “this may require collaborating with other brands who
product contains 40% recycled material”, you source the same materials from the same
want to ensure that the content of that particular supplier, to reach a critical mass that will make it
product is exactly 40% recycled material. Using worthwhile for that supplier to engage in Material
Mass Balance, you would only be able to claim Traceability.
something along the lines of “This brand uses While digital traceability systems provide the
40% materials from recycled sources.” CoC data at a digital level, technologies that
trace the physical product, as covered earlier in
the playbook, are also critical to get more
How? accurate results. The best approach will be to
To achieve Material Traceability, brands must combine several sources of data and knowledge.
collaborate with suppliers to document all of Ultimately, the more accurate, verified data that
the materials that go into a product through can be gathered on the full value chains of
the manufacturing process, along with reports products and materials, the better-equipped
and declarations that substantiate claims at fashion businesses will be to take meaningful
each step.

action and accelerate sustainable

For example, if you want to make a material transformation.

specific claim related to leather, saying “This

product uses leather that is chrome-free” the
leather tanner must provide a facility certificate
confirming that they are not using chrome, as Product type: Garment

well as a quality report for the batch of leather Facility Name & Country

getting shipped downstream which confirms that Product Name: Men’s Shirt

Product UID: PD01990​

the leather is chrome-free. This must be linked Used Quantity (kg): 7500
with the finished product to make the claim. To
achieve this, downstream suppliers should record
the usage of the specific chrome-free leather at
Product type: Fabric

every step till the finished product.

Facility Name & Country

Fiber forward traceability that uses the Material Name: Cotton Fabric​

Product Segregation CoC model provides you Material UID: RM00090

Lot No: 20080​

with data on each batch, which is available when Used Quantity (kg): 9500
you need to substantiate claims for sales and
marketing, or prove a batch’s compliance with
regulations when it goes through customs and Product type: Yarn

into the market. Facility Name & Country

Achieving Material Traceability requires some Material Name: Cotton Yarn

Material UID: RM00090

level of tech maturity because, in order to gather Lot No: 100490​

millions of data points, you need a system that Used Quantity (kg): 12000

can process this amount of information. To make

the process smoother, we recommend having all
the data on the product style, material and PO
Product type: Fiber​

Product type: Fiber​

available in a PLM or an ERP system. Facility Name & Country

Facility Name & Country

Material Name: Cotton fiber​

Material Name: Cotton fiber​

Material UID: RM00089​

Material UID: RM00089​

Lot No: 50700​

Lot No: 50700​

Used Quantity (kg): 10000 Used Quantity (kg): 10000

What’s Next?
What’s Next? 61

What’s Next?
The systemic issues facing the fashion industry cannot be
solved by single individuals or organizations. It calls for buy-in
and collaboration of the entire ecosystem, from brands to
standards bodies, suppliers to farms, and beyond. The industry
has the will to solve these problems, and now we have the tools.

Sustainable transformation doesn’t happen Fashion brands have the data they need

overnight, but the more accurate, granular to start tracing their supply chains, and tech
data you have, the faster your transformation platforms are quickly rising to the challenge.
will be. No matter what your company policies Traceability providers are not stand-alone
and commitments are, ultimately consumer systems. They are expanding their ecosystems
demand, regulations, and market dynamics to incorporate other sustainability solutions
will push fashion businesses to achieve
and data providers, taking fragmented data
system-wide traceability.
and making it visible and accessible for
everyone, all in one place.

Many of us are talking about the issues in If brands start to adopt this and work with
fashion’s supply chains, but there are also sustainability data, alongside product design
issues with overconsumption and circularity and inventory management, then they will get
that we need to address. We all know there closer to understanding the impact of their
are problems, but until data is available and business, and changing it for the better.
accessible to everyone, we can’t identify When the fashion industry works collectively
them or prioritize them correctly. In the towards a shared goal of sustainable
coming years, we need to focus more on transformation, there’s no telling what we can
creating data visibility for the end-to-end achieve. Some brands will be further along on
impact of our choices. We should be looking this journey than others, but everyone can
at the full cycle from fiber to end of life and make a real difference by making the right
back to fiber, considering not only the impact choices based on solid data. Our hope is that
of production itself, but the length of a this playbook helped you see how you can take
product’s lifespan before it’s reused or the next step in your journey to accelerate
recycled. The data about the entire value sustainable transformation.
chain and its impact will be much more
transparent and will help drive
transformation in a focused manner.

Madhava Venkatesh
CTO and Co-Founder of TrusTrace
Glossary of Traceability Terms 62

Glossary of Traceability Terms

Batch-level or Lot-level data: Granular information pertaining Life Cycle Assessment (LCA): A methodology for
to a defined quantity of a material or product that is processed assessing environmental impacts associated with all the
together stages of a product’s life, from manufacturing to disposal
Bill of Material (BOM): This is a list of the raw materials and Legislation: Laws and regulations made by a
components, plus the quantities of each, needed to government that businesses must adhere to
manufacture a product Material-based claims: This refers to any declaration
Blockchain: A digital ledger of transactions that is duplicated made by a business relating to the materials used to
and distributed across the entire network of computer manufacture their products
systems Product Backward Traceability: Otherwise known as
top-down traceability, this refers to the process of
Corporate Social Responsibility (CSR): This is a form of self-
tracking the supply chain of a product after it has been
regulation that businesses use to instigate philanthropic,
manufactured
activist, or charitable initiatives whereby they engage in or
support volunteering practices Product Lifecycle Management (PLM): Organizations
use this to develop new products, as well as track and
Certificate of Origin: This is proof that a product was share data along the entire supply chain.
manufactured in a specific country or region, used to comply
Purchase Order (PO): This is a document issued by a
with due diligence legislation.
brand to a supplier which indicates the styles, quantities,
Chain of Custody (CoC): As materials move through the value and prices for products they have purchased.
chain, a Chain of Custody can be created by each handler by
Real-time data: This refers to when information is
recording critical information about the lot and its associated collected about a material or product, in this case, it is
claims. recorded as the item moves through the value chain.
Circularity: A model of production and consumption that Scalability: This refers to the ability to expand or
focuses on sharing, leasing, reusing, repairing, and recycling increase the implementation of a system or operation to
existing materials and products for as long as possible a system-wide level.
Compliance: Adhering to requirements that are decreed by Soft technology: This refers to digital B2C solutions like
laws and regulations. rental and resale platforms, as well as B2B solutions like
traceability software.
Decentralized Data: The process of attaching data to a
product, rather than the owner of a product, using blockchain Standardized data: This refers to the process of
technology establishing common identifiers so that multiple systems
auditing different or overlapping issues can exchange
Digitization: The process of converting, streamlining and and collate information.
converging analogue information from emails, PDFs and Excel
spreadsheets into a digital format on a unified system. Supplier: A supplier is any actor within a supply chain
that is involved in the sourcing, manufacturing, or
Due Diligence: The process of auditing your supply chain to transportation of a material or product
identify, mitigate, and account for potential environmental and
Sustainable financing: This refers to the acquisition of
social issues
financial resources to implement improvements to
Enterprise Resource Planning (ERP): A software system that facilities with a businesses supply chain
allows brands to manage everyday business operations like Third-party audits: This refers to independent groups
accounting, supply chain operations, compliance and risk that perform on-the-ground assessments of facilities to
management ensure that they’re working in compliance with
Environmental, Social, and Corporate Governance (ESG): A ​ certifications
measurement that companies use to evaluate the extent to Tier: Supply chains are commonly divided into tiers
which their operations impact three core pillars of sustainability where different functions are performed to transform raw
material into a finished product.
Evidence request: The process of contacting suppliers, either
digitally or manually, to ask for information about their Traceability: The ability to trace the history, application,
operations in relation to a specific risk area or location of a material or product through recorded
identifications
Fiber Forward Traceability: This refers to the bottom-up
process of tracing a product from the raw material phase to the Transparency: The relevant information that is available
end product in real-time to all elements of the value chain in a standardized way,
which allows common understanding, accessibility,
Fragmentation: This refers to data that has been broken up clarity and comparison
into different formats or across different platforms, leading to
Weight-based calculations: This refers to the
inefficiencies and inaccuracies
measurement of a material or product by its weight in
Hard technology: This refers to asset-intensive, physical, order to determine the content make-up and instances of
science-based technology, including innovations that integrate material wastage.
into existing production systems.
For more information and insights, or to start your

traceability journey, visit TrusTrace.com.