Key considerations for implementing California’s SB 707

California’s Responsible Textile Recovery Act of 2024 (SB 707) introduces the first extended producer responsibility (EPR) program for apparel and textiles in the United States, with potentially transformative implications for the industry.

France, which implemented its textile EPR law in 2007, has established the world’s longest-running system for fashion’s end-of-life impacts. As California moves forward with SB 707, regulators, producers, and other stakeholders may find key insights from France’s experience.

Our alert provides a comparative review of SB 707 and France’s framework, revealing both commonalities and distinctions that may inform implementation strategies.

Background of the United States’ and France’s EPR frameworks

Both California and France center their EPR frameworks on the principle that producers – not taxpayers or local governments – are responsible for the financial and operational responsibility for managing their products’ end-of-life impacts.

In France, this has translated into a robust, nationwide system where nearly all producers join a collective Producer Responsibility Organization (PRO) called Refashion. Refashion is a government-approved and industry-financed private nonprofit (previously called Eco-TLC), that coordinates the collection, sorting, reuse, and recycling of textiles.

California’s SB 707 also requires producers to join or form a PRO by 2026. Stewardship plans must address collection, recycling, repair, and reuse. In July 2025, three industry trade groups – including the California Retailers Association, the American Apparel & Footwear Association, and the National Retail Federation – signed a memorandum of understanding to jointly establish an independent PRO dedicated to textiles, in compliance with SB 707.

Overview of both French and United States textile EPR laws

France’s textile EPR law and California’s SB 707 both establish comprehensive EPR systems for textiles; however, they function in different settings.

France’s Anti-Waste and Circular Economy Law

France, building on European Union regulations and the country’s EPR program, adopted the Anti-Waste and Circular Economy Law (Anti-Gaspillage pour une Économie Circulaire, or AGEC) in 2020. The AGEC Law applies to a wide range of “producers,” defined as any person or entity that professionally manufactures, imports, or introduces textile products to the French market – whether for sale or free distribution. This includes manufacturers, importers, distributors, and anyone else promoting textile products in France. Refashion oversees the system.

Under the AGEC Law, producers must finance and manage the collection, sorting, reuse, and recycling of textiles. They also can pay eco-modulated fees adjusted based on product sustainability. The law prohibits the destruction of unsold goods and enforces compliance through financial penalties and public registers for confirming EPR registration status and other data.

California’s SB 707

Passed in 2024, California’s SB 707 is the first law in the United States designed to promote circularity in the fashion and apparel industry. Similar to France’s AGEC Law, SB 707 requires producers – including online and out-of-state sellers – to join a PRO and create stewardship plans covering collection, repair, reuse, and recycling. SB 707 also incorporates eco-modulated fees, producer reporting requirements, consumer education provisions, exemptions for small and secondhand sellers, and collaboration with local governments and repair organizations.

While France does not fully exempt small producers, its requirements are being phased in according to producers’ revenues and product volumes. Qualifying sellers pay a flat fee of EUR75 per year while still meeting other obligations. California’s Department of Resources Recycling and Recovery (CalRecycle) is responsible for enforcing SB 707, which includes significant penalties for noncompliance.

Lessons from France’s system

Both SB 707 and France’s AGEC Law shift end-of-life management to producers and aim to promote circularity. France’s approach, however, is more mature and has a strong regulatory foundation within the European Union. For instance, the European Union Waste Framework Directive sets minimum standards for EPR programs and requires member states to adopt EPR laws and legal frameworks. The European Union has also adopted comprehensive circular economy action plans that set targets and strategies for waste prevention, reuse, and recycling across Europe. France’s AGEC Law aligns with these initiatives and is now a binding obligation in the European Union.

California’s SB 707 is a pioneering effort in the United States, which does not have a unified federal policy on textile waste and sustainability. Instead, individual states, such as California, enact regulations. This fragmentation creates challenges, but also reveals opportunities for policy innovation.

As California moves SB 707 toward implementation, companies may wish to consider the following lessons from France’s experience:

1. Eco-modulation: France’s EPR system imposes eco-modulated fees, meaning that producers’ fees to the PRO are adjusted based on the environmental sustainability of their products. Products with greater durability, recyclability, and recycled content are charged lower fees, while less sustainable products incur higher fees. California adopted a similar approach for SB 707, which will eco-modulate producer fees based on clearly defined and enforceable criteria and on the state’s ability to adapt to advances in product design and recycling technologies.
   
   
2. Collection and recycling infrastructure: France’s success has stemmed from accessible recycling options and investment in extensive infrastructure, including the establishment of a network of more than 44,000 textile collection points developed in collaboration with local authorities and social enterprises. This network has enabled high collection rates but also revealed challenges – especially in sorting blended textiles and managing exported used clothing.
   
   
3. PRO structure: SB 707 allows for multiple PROs, requiring producers to join or form a PRO approved by CalRecycle. France has a similar system, where producers can organize in PROs or implement individual systems for approval. In practice, the creation of a centralized French PRO (Refashion) has streamlined regulatory compliance.
   
   
4. Clear and inclusive producer definition: France’s EPR system succeeds in part due to a clear, inclusive definition of “producer.” SB 707 mirrors this by defining “producer” broadly to include manufacturers, brand owners, importers, and, in the absence of these, distributors, retailers, or wholesalers selling into California.
   
   
5. Stakeholder engagement: France’s system underscores the importance of consumer engagement and robust oversight. Tools such as the Triman logo have raised awareness to guide consumers on how to sort and recycle products and packaging, but influencing long-term consumer behavior remains challenging. Both the AGEC Law and SB 707 require annual reporting with public transparency to support enforcement and program improvement.
   
   
6. Reuse and repair partnerships: France’s EPR system supports reuse and social enterprises. The European Union Waste Framework Directive, which France follows, prioritizes reuse over recycling in the waste hierarchy and requires that collected textiles be sorted to maximize reuse before recycling or energy recovery is considered. Additionally, the AGEC Law requires Refashion to propose and implement an action plan to develop the reuse of used textiles. The action plan must be submitted to the relevant ministries and supported by a dedicated fund. Similarly, SB 707 emphasizes repair and reuse, requiring PROs to prioritize these activities and to partner with secondhand markets and nonprofit thrift stores. The law also mandates incentive payments, grants, and market-development investments to support infrastructure for repair and reuse.

SB 707’s expansion

Although SB 707 is new, it incorporates key lessons from France. In particular, France has faced challenges with noncompliant online sellers. SB 707 addresses this by requiring online marketplaces to report third-party sellers with more than USD1 million in sales, provide compliance information, and ensure that only compliant producers’ products are sold in California. This enforcement strategy is designed to close gaps and ensure a level playing field.

SB 707 also significantly expands annual reporting requirements, including detailed data on products sold, collected, reused, and recycled – broken down by fiber type and other relevant categories. SB 707 also requires reporting on market conditions, barriers in end markets, financial incentives, funding sources, education, and outreach. While France’s AGEC Law includes an annual reporting requirement, the level of transparency and granularity under SB 707 is more robust, focusing chiefly on annual declarations of volumes of products placed on the market (in aggregate by category of product rather than by material) and development of five-year action plans concerning eco-design and textile waste prevention.

Looking ahead

Major changes to textile producers, brands, and retailers worldwide are expected. Compliance with new EPR laws will require careful attention to timelines, investments in sustainable design, and the development or support of recycling infrastructure.

Success will also depend on robust engagement with both consumers and supply chain partners. Staying ahead of regulatory deadlines and embracing the principles of the “circular economy” will be key for continued market access and brand reputation.

Key dates for SB 707 implementation include:

• March 1, 2026: CalRecycle must approve at least one PRO
  
  
• July 1, 2026: All qualifying producers of apparel and textiles sold in California must join or form a PRO
  
  
• July 1, 2028: CalRecycle must adopt implementing regulations for the program; PROs must submit a stewardship plan within 12 months of the regulations being adopted
  
  
• July 1, 2030: All producers must operate under an approved stewardship plan or face penalties (up to USD50,000 per day for intentional violations)

Additional considerations:

• Annual reporting: PROs must submit annual reports to CalRecycle detailing activities the PRO has taken to prioritize the use of sorting and recycling facilities closer to the point of product generation, compliance, and progress
  
  
• Online marketplaces: Ongoing annual obligation to report third-party sellers exceeding USD1 million in sales and ensure they are informed of compliance requirements

Conclusion

France’s system demonstrates the potential of EPR laws to improve textile waste management, while also highlighting the challenges of building a circular apparel industry. California’s SB 707 is poised to lead in the United States, but its success may hinge on the ability to learn from Europe, anticipate obstacles, and build strong partnerships across the value chain.

Stakeholders in the United States may wish to engage early with regulators and PROs, invest in sustainable product design, develop partnerships for collection and repair, and prepare for increased transparency and consumer engagement obligations.

As the global landscape for textile EPR continues to evolve, ongoing attention to developments in Europe will be key for staying ahead of emerging trends and regulatory expectations.

Learn more

DLA Piper’s Plastics practice is engaged with stakeholders across the industry and has supported stakeholders in every packaging EPR program enacted to date.

For additional information, please contact any of the authors.