“Complex” shouldn’t necessarily mean “confusing”—although it usually does. With highly complex sustainability regulations, reporting requirements and voluntary frameworks multiplying across the textile industry, many perplexed brands are asking the same question: Where should we focus first?
That challenge was the focus of the recent Texworld NYC panel Clarity in Complexity: Navigating Sustainability Frameworks in Practice, moderated by Devon Rufo, founding partner of Reframe Partners. Joining the discussion were Rachel Kibbe, CEO and founder of Circular Services Group and American Circular Textiles (AmCirc); Earl Shank, senior manager of supplier responsibility and traceability at Tapestry; and Ben Tomkins, regional vice president, Americas, at Oritain.
The elephant in the room was that navigating sustainability and shifting regulations aren’t just complex, they’re exhausting.
“One of the biggest challenges is ‘framework fatigue,’ especially at the state level with extended producer responsibility bills where things get complex really quickly,” said Kibbe. “Policy is complex by design. What we focus on is making it as simple and understandable as possible for companies, so they know what’s coming and how to prepare.”
Tapestry, which recently achieved its public goal of 95% raw material traceability across brands including Coach and Kate Spade, reduces framework fatigue by prioritizing data that will move the needle in the supply chain.
“We’re not engaging in a data gathering exercise,” Shank said. “We’re actually getting to that action and using that data to inform business decisions, so that we’re building resiliency in our supply chain—reducing impact and reducing risk.”
Oritain cites framework fatigue as a “duplication of efforts,” whether it be reporting, audits or labor hours, and the company looks into different metrics to ultimately satisfy all of the same frameworks. “Looking at where there’s harmonization across all those different standards frameworks is super important. So as you can see, we’re joined by solutions, action and policy,” said Tomkins.
Documentation Isn’t Enough
Drawing from Oritain’s vast experience working with clients, Tomkins cautioned that there’s an over reliance on paper-based documentation, which “can be misused and adulterated in the age of AI,” and is no longer enough as regulators increase scrutiny. Documentation that might not be reliable can also lead brands into “a false sense of security.”
An Oritain study found that over 87% of U.S. companies stated they did trace most or all of their cotton supply chain, but when Oritain tested anonymized samples from retail, they found that 90% of brands had at least one garment with cotton from a banned region.
“We’re seeing a significant shift away from what brands state to what they can demonstrate,” he said. “Progress is key but be careful of focusing on traceability as a process versus verification as evidence.”
When thinking about where to start, companies should first prioritize regulations that directly affect market access or legal compliance. “If there’s a regulation that you absolutely need to comply with, you’ve got to spend your time and attention there,” Shank said. “Then it becomes ‘pick your own adventure’—engaging with executives, benchmarking against peers, recognizing internal constraints and supply chain leverage, and summarizing it all for the organization.
Tapestry builds compliance work around three pillars—identification, measurement and management. “Once we identify where our fibers and materials come from, how do we substantiate that? How are we doubling down on documentation and evidence? Once we have on-site audits, we layer on geo-spacial data about national trends that have to do with risk and impact. And finally, how are we investing in interventions and building capabilities within our own supply chain?”
Such granular data helps when things ultimately evolve, and it’s important to mitigate surprises. “I don’t want other people—whether that’s a regulator or an activist organization—to know more about my supply chain than I do,” he said.
Kibbe stressed incentives as a powerful tool and highlighted AmCirc’s work supporting Section 232 of the Americas Act, which proposes federal incentives to strengthen domestic textile recycling and nearshoring, rather than penalty-based ones.
“We are very incentive-forward as an organization,” she said. “We’re really pushing for dollars and incentives at the federal level.”
She cited how the administration largely catalyzed the renewable energy sector and electric vehicles. As the apparel industry is larger than the passenger vehicle industry, AmCirc proposed a comparable amount—$14 billion in grants and loans, plus a 15% tax credit for civilian activities.
Another recurring theme was the importance of industry standards, where common data standards could reduce duplication and make compliance more seamless and efficient across supply chains.
“If everyone has a standard, or no one adopts a standard, you really don’t have a standard,” Shank said. “Right now, Tapestry is continuing to invest in and push to roll out an approach called the Global Traceability Framework for Beef and Leather. Everyone feels like they need to come up with their own way of doing this in running an RFP and adopting a platform that might support your traceability. Many folks don’t know to ask about what is the underpinning of how that platform is going to perform that function.”
Standards also make things easier for regulators. “Legislation is often sort of vague, but [regulators] don’t like not being able to measure if something is able to be accomplished because that just makes them look bad. Standards are a really important place in making sure all these tools can get done,” said Kibbe.
Start Early with Voluntary Objectives
Looking ahead, the panelists encouraged brands to start doing voluntary initiatives rather than wait for regulations to be finalized. Tomkins recommended beginning with a single product or material and scaling from there, even simulating mock detentions to have a course correction plan at the ready.
“We’ve had the horrible calls on Friday afternoon where a brand had product detained and were trying to get it back into circulation and into stores, and the speed of insight became critical because you only had 30 days to contest that rebuttable presumption to CBP,” said Tomkins. “So the frenzy of verification activity is at the fabric mill or tannery, not as a finger-pointing exercise, but where it’s early enough to remediate those issues.”
At Tapestry, it’s not just about answering to government authorities, but appealing to corporate higher-ups via a system of “raters and rankers.” Sustainability teams then have the opportunity to leverage scores to advocate for improvements or investments or interventions within the organization.
Such internal, voluntary preparedness also helps draw alignment across divisions, across departmental functions, and help prepare for regulations that aren’t even here yet. An internal requirement can also help as an internal stepping stone. “Knowing that EUDR is going to be coming down the track, what are we doing now voluntarily to accelerate our work towards meeting that when it does come into effect?” said Tomkins.
Kibbe had a similar warning, urging companies to build internal expertise before compliance becomes mandatory: “If your position as an organization is just we’ll do what we’re told, now is also the time to understand what is coming down the pike because it is super complex.”
