NY Fashion Act: Supply Chain Due Diligence Law¶
New York is the fashion capital of the United States, and the New York Fashion Sustainability and Social Accountability Act (originally introduced in 2021 as Senate Bill S7428 / Assembly Bill A8352 and reintroduced in 2023) is the most aggressive state-level fashion regulation proposed in the country. If passed, it would require fashion brands and retailers doing business in New York with more than $100 million in global revenue to map their supply chains, disclose environmental and social impacts, and set binding targets for improvement.
The NY Fashion Act is modeled in part on the French Duty of Vigilance Law (LdV) and the EU's CSDDD — but specifically tailored to the fashion, footwear, and apparel industry. On the Sustalium platform, we are already seeing fashion brands begin to structure their supply chain data in anticipation of the legislation, because the mapping and disclosure requirements mirror what their European operations are already doing under CSRD and CSDDD.
What the NY Fashion Act Requires¶
The Act targets the fashion industry's most significant environmental and social impacts. Covered companies — those with more than $100 million in global revenue doing business in New York — would be required to:
1. Supply Chain Mapping¶
Map at least 50% of their supply chain by volume, across all tiers, identifying the names and locations of suppliers, subcontractors, and processing facilities involved in the production of their goods. This mapping must cover all stages of production, from raw material sourcing through final assembly.
2. Environmental and Social Due Diligence¶
Conduct and publicly disclose due diligence on: - Greenhouse gas emissions across the supply chain, aligned with the Science Based Targets initiative (SBTi) framework - Water consumption and water pollution impacts in material production and processing - Chemical management, including restricted substance compliance and wastewater treatment at supplier facilities - Labor conditions, including wages, working hours, freedom of association, and health and safety at all supplier tiers
3. Public Disclosure¶
Publish an annual report on the company's website detailing: - The supply chain mapping results - The environmental and social impacts identified - The corrective actions taken or planned - Progress toward binding reduction targets
4. Binding Targets¶
Set and publicly commit to science-based environmental targets, including greenhouse gas reduction targets aligned with the Paris Agreement. Companies that fail to meet their targets would be subject to fines of up to 2% of annual revenue — a penalty mechanism directly borrowed from the GDPR enforcement model.
Scope: Who It Would Cover¶
The NY Fashion Act casts a wide net. The legislation defines covered entities as fashion retailers and manufacturers doing business in New York with global revenue exceeding $100 million. This threshold captures not only the obvious targets — fast fashion giants and luxury conglomerates — but also mid-market brands, department store private labels, and footwear companies with significant NY retail or wholesale presence.
Critically, the obligation extends to the entire supply chain, not just Tier 1. A fashion brand selling in New York cannot limit its due diligence to the cut-and-sew factory — it must extend upstream to fabric mills, dye houses, fiber producers, and raw material sources. This is the same upstream mapping challenge that apparel companies face under the EU's CSRD, CSDDD, and the German Supply Chain Act (LkSG).
How It Compares to EU Frameworks¶
| Aspect | NY Fashion Act | EU CSDDD | French LdV |
|---|---|---|---|
| Scope | Fashion/apparel only | All sectors | All sectors |
| Revenue threshold | >$100M global | >€450M EU | Based on employees (5K/10K) |
| Targets | Mandatory binding targets | Climate transition plan | Risk mitigation actions |
| Penalties | Up to 2% of annual revenue | Fines + civil liability | Court-ordered compliance |
| Specificity | SBTi-aligned GHG, water, chemicals | Human rights + environment | Human rights + environment |
The NY Fashion Act is narrower in scope (one industry) but more prescriptive in its environmental requirements — specifically mandating SBTi-aligned targets for GHG reduction. No other supply chain due diligence law globally mandates a specific target-setting framework.
What Fashion Brands Should Do Now¶
Even if the NY Fashion Act has not yet been enacted into law, fashion brands selling in New York should not treat it as a hypothetical. The supply chain data requirements are virtually identical to what European operations already require under CSRD and CSDDD — and New York's market size makes the legislation a de facto national standard if the largest US market for fashion adopts it.
Practical preparation steps:
- Map your supply chain now. If your European operations have already mapped suppliers for CSRD or CSDDD compliance, extend that mapping to your US product lines. The data structure is the same.
- Align GHG reporting with SBTi. The Act's specific reference to the SBTi framework makes it the expected standard. Brands that have already set SBTi targets have a significant head start.
- Consolidate supplier chemical and water data. The Act's environmental requirements go beyond what most fashion brands currently collect from suppliers. Implement structured supplier data collection for chemical inputs, wastewater treatment, and water consumption at the fabric-mill and dye-house tiers.
- Structure compliance data for public disclosure. Unlike internal compliance audits, the NY Fashion Act mandates public annual reporting. The compliance documentation you maintain internally must be structured for external publication.
How Sustalium Supports NY Fashion Act Preparation¶
The data collection problem at the heart of the NY Fashion Act — mapping multi-tier fashion supply chains, collecting environmental data from fabric mills and dye houses, and structuring it for public disclosure — is exactly the problem Sustalium's platform is built to solve.
Sustalium's fashion supply chain compliance platform supports:
- Multi-Tier Supply Chain Mapping: Structured supplier profiles that capture every tier of your fashion supply chain, from fabric mills to dye houses to trim suppliers to final assembly — with supplier name, location, certification status, and production volume for each.
- Environmental Data Collection: Supplier-facing portals where your mills and dye houses can input chemical inventories, wastewater data, water consumption, and energy use — replacing email-based data collection that produces inconsistent, non-comparable results.
- SBTi-Aligned Reporting: Structure your GHG data in SBTi-compatible formats, with supplier-level emissions data mapped to Scope 3 categories relevant to fashion production.
- Public Disclosure Pages: Generate public-facing compliance pages that satisfy the NY Fashion Act's annual reporting requirement — structured, verifiable, and linkable — rather than publishing a static PDF report on your website once a year.
Prepare for NY Fashion Act Before It Becomes Law
The largest fashion market in the US is moving toward mandatory supply chain due diligence. Brands that build their data infrastructure now will not be scrambling when the legislation passes.
With Sustalium, build your fashion supply chain compliance profile for just €10 per document.
Frequently Asked Questions¶
Has the NY Fashion Act been passed into law?
As of 2026, the NY Fashion Act has been reintroduced but not yet enacted. However, the legislative sponsors have broad support, and the EU's adoption of CSDDD and the French LdV enforcement record provide strong precedent. Most fashion brands treat it as a question of when, not if.
How does the NY Fashion Act differ from California's SB 253/SB 261?
California's SB 253 and SB 261 require climate emissions disclosure and climate risk reporting from large companies doing business in California, across all sectors. The NY Fashion Act is industry-specific (fashion/apparel only) and broader in scope — covering water, chemicals, and labor conditions in addition to GHG emissions. The two frameworks overlap on climate disclosure but the NY Fashion Act demands significantly more operational supply chain data.
Does the NY Fashion Act apply to non-US brands?
Yes. The revenue threshold is global revenue over $100 million, and the trigger is doing business in New York. A European or Asian fashion brand with a retail store, wholesale account, or e-commerce sales in New York would be subject to the Act.
Last updated: July 21, 2026