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New York’s Climate Corporate Data Accountability Act for Fashion

Lidia Lüttin — Mon, 30 Mar 2026 09:06:20 GMT

Status: Passed NY Senate, pending Assembly vote and Governor's signature

TL;DR

WHAT: Mandatory public disclosure of Scope 1, 2, and 3 emissions, aligned with the GHG Protocol and subject to third-party assurance.
WHO: Companies with >$1B global revenue doing business in New York.
WHEN: Scope 1 & 2 reporting starts in 2028 (on 2027 data), with Scope 3 following in 2029 (on 2028 data).

With California’s SB 253 already setting requirements for corporate climate reporting, New York is advancing a similar emissions disclosure framework through the Climate Corporate Data Accountability Act (S9072A).

The bill is currently proposed legislation and needs to pass Assembly and be signed into law by the Governor. If adopted, in-scope fashion companies would begin reporting Scope 1 and Scope 2 emissions from 2028, with Scope 3 reporting starting in 2029.

This timeline means apparel and footwear brands should begin preparing now by building data collection processes across operations and supply chains, aligning calculations with the GHG Protocol.

Looking for a Carbon Accounting solution? Find our complete, hands-on guide to Carbon Accounting and the GHG Protocol for apparel and footwear brands here.

Now, let’s break down New York’s Climate Corporate Data Accountability Act!

What Does New York’s Climate Corporate Data Accountability Act Mean for Fashion Brands?

The New York Climate Corporate Data Accountability Act (S9072A) introduces a mandatory greenhouse gas (GHG)emissions disclosure requirement for large brands doing business in New York.

Under the bill, fashion brands must annually measure and publicly disclose their emissions across:

Scope 1 – direct emissions from owned or controlled operations.
Scope 2 – indirect emissions from purchased energy.
Scope 3 – indirect emissions across the value chain.

Emissions must be calculated using GHG Protocol Corporate Standard and Scope 3 Standard. This means apparel and footwear brands may use a combination of primary data, secondary data, and modeled data (including industry averages), in line with GHG Protocol guidance for Scope 3.

To reduce duplication, brands can submit existing reports prepared for other frameworks or regulations (such as California SB 253or Corporate Sustainability Reporting Directive), as long as those reports meet the requirements of this law.

Emissions Data Disclosure Made Public

Reporting brands must publicly disclose their emissions data through a centralized reporting portal (which will be set in place by the end of the next year by the Department of Environmental Conservation).

All reported emissions data will then be made publicly available through a digital platform, where consumers can access company-level disclosures, aggregated datasets, and multi-year trends. Therefore, each disclosure must clearly identify the reporting entity by including its legal name, trade or assumed names, subsidiaries, and associated branding such as logos.

Which Apparel and Footwear Brands Will Be Affected by New York’s Climate Corporate Data Accountability Act?

The Act applies to large apparel and footwear brands doing business in New York. A fashion company is in scope if it meets both conditions:

Business activity in New York: This means the brand operates in New York and generates revenue from activities in the state. This applies broadly to fashion brands, including through retail, wholesale, or e-commerce sales.
Revenue threshold: The brand has more than $1 billion in total global annual revenue.

This applies to both U.S. and international brands.

What Is the Compliance Timeline for Fashion?

The Act introduces a phased implementation, with reporting and assurance requirements increasing over time.

By December, 2027: The Department of Environmental Conservation (DEC) is expected to establish and publish the final reporting framework and technical guidelines.
2028 (Initial reporting phase): Brands begin disclosing Scope 1 and Scope 2 emissions on 2027 data.
2029 (Scope 3 Expansion): Reporting requirements extend to Scope 3 emissions.
Scope 1 and 2 assurance: limited assurance in 2028, reasonable assurance in 2032

Note: For apparel and footwear brands with complex global supply chains, the Scope 3 requirement is particularly significant. It requires collecting data beyond direct operations, including raw material sourcing and manufacturing at supplier facilities, making early preparation necessary despite the 2028 deadline.

Penalties for Non-Compliance

The Act allows the New York Attorney General to impose civil penalties for non-compliance, including non-filing, late filing, or failure to meet reporting requirements. Penalties can reach up to $100,000 per day, with a maximum of $500,000 per reporting year.

In enforcing penalties, the Attorney General must consider both the company’s past compliance and whether it made good faith efforts to meet the requirements.

For Scope 3 emissions, the law provides some flexibility. Companies are not subject to penalties for misstatements if the disclosures are made with a reasonable basis and in good faith. In addition, between 2029 and 2032, penalties related to Scope 3 apply only in cases of non-filing, not for inaccuracies in the data.

Carbonfact: Carbon Accounting Platform for Fashion

Carbonfact isCarbon Accounting platform built for fashion, helping brands like Everlane, Carhartt, and U.S. Polo ASSN to measure, report, and reduce their carbon emissions.

Here is how Carbon Accounting process looks with Carbonfact platform:

Flexible data ingestion: platform ingests energy bill, facility information, product data, BOMs, care labels, purchase orders, supplier information, and factory data in whatever format you already use.
Automated data cleaning: Carbonfact automatically cleans and consolidates your data, minimizing manual effort and errors.
Data gap filling: we fill missing values using T1–T5 supplier data, verified through running over 50 million apparel and footwear LCAs.
Auditability: view the source, method, and emission factor behind every calculation. Aligned with GHG Protocol and reviewed by PwC.
Accurate data: 150K+ fashion-and region-specific emission factors ensure accurate results – even when your data isn’t perfect.
Factories: a powerful platform feature where you can easily manage and update your factories' energy data directly on our platform heat mixes, meters, and utility bills.
Carbonfact AI Copilot: AI assistant inside the Carbonfact platform that answers questions about features, science, and methodology, with every reply linking back to the official documentation.

Curious to see how Carbonfact helps apparel and footwear brands report carbon emissions? Read all about it in Samsøe Samsøe 2024 Impact Report– Page 15!

Resources

Senate Bill S9072A– The New York State Senate

March ‘26 Product Release: Better Company Modeling Initiatives

Martin Daniel — Thu, 26 Mar 2026 14:27:32 GMT

Company Modeling is Carbonfact’s tool for planning your decarbonization strategy – mapping out the impact of material switches, supplier changes, and volume shifts before you commit to them. Over the past weeks, we’ve built three improvements that make the tool more accurate, more realistic about business growth, and we’ve improved the way initiatives are tracked.

The Carbon Footprint of TPU Midsoles

Laurent Vandepaer, PhD — Mon, 16 Mar 2026 11:14:01 GMT

("You Ask, We Answer" – brought to you by Carbonfact's Head of Science. Each week Dr. Laurent Vandepaer, PhD together with Carbonfact's Science Associate Vincent Carrières answers one of your questions about sustainable materials, manufacturing impact, and energy transition in the apparel and footwear industry.

What is the Best DPP Software for Fashion Brands? A Buyer's Comparison

Lidia Lüttin — Fri, 27 Feb 2026 09:19:05 GMT

While the exact requirements are still evolving, the direction of travel is clear: The Digital Product Passport will become a core part of how apparel and textile products are assessed by consumers, similar to the already-existing NutriScore for food. For apparel (and later, footwear), DPP is expected to enter into force in mid-2027, with an (not definitive) 18-months grace period before compliance becomes mandatory.

February ‘26 Product Release: Copilot for Explorer, Custom Homepage & Expanded DPP Traceability

Martin Daniel — Wed, 25 Feb 2026 11:31:57 GMT

This month, we’re introducing a major upgrade in how you access insights on your environmental data.

The French Textile Eco-Score: 2025 - Key Updates and What Fashion Brands Need to Know

Lidia Lüttin — Wed, 21 Jan 2026 23:15:00 GMT

Status: ✅ Approved law

The French Eco-score, part of the 2021 Climate and Resilience Law, is also known as “environmental labeling” or “affichage environmental” and has been officially renamed to "Environmental Cost" or “cout environmental”.

On 4th September, Ecobalyse, France’s official environmental cost calculator, announced in a webinar that the Ministry of Ecological Transition has now approved the final texts for Environmental Cost, and its entry into force begins on October 1st, 2025.

Slide with timeline from the webinar on 4th September. Find the slides here.

If your apparel company — whether French or foreign — operates within the French market, this marks an important moment to start preparing for implementation and alignment with the new requirements.

Let’s dive into all the details or watch this 15-minute crash course:

Find the French version of this article here 🇫🇷

What is the French Eco-Score?

The French ‘Environmental Cost’ (French: Coût Environnemental), is part of France’s affichage environnemental (environmental labeling) scheme for textiles, introduced under the AGEC law and formalized by the 2021 Climate and Resilience Law. It is a methodology developed under the French government’s environmental labelling program, coordinated with ADEME (French Agency for Ecological Transition), to assign a single score (in environmental points) to the impacts of textile products in France.

This methodology for assessing and communicating the environmental impacts of textile products is based on life cycle assessment (LCA) and evaluates 16 environmental indicators. Each indicator is normalized and weighted according to the official methodology.

The weighted results are summed, and additional parameters such as durability and microfiber release are added to produce the final score in environmental points, which is displayed on a consumer-facing textile label. The higher the score, the bigger the environmental impact the product has.

Timeline for Textile and Fashion Brands

The final Decree, relating to the methods of calculating and communicating the environmental cost of textile products, was published on September 6th, 2025 - you can find it here. Eco-Score took effect on October 1, 2025. The latest changes to the texts are mostly editorial and structural, with no major policy changes.

1st October 2025: Entry into force. Only brands may voluntarily calculate and submit their product Eco‑Scores to the public portal.
From October 2026: If the fashion brand has not yet published a score themselves, any third party, e.g. retailers, NGOs, will be able to publish the Environmental Cost on behalf of textile brands – without needing the brand’s prior approval. From October 2026, as well, if the brand communicates any other environmental score (such as carbon footprint on the e-commerce store), then displaying the Environmental Cost label becomes mandatory.

Who Needs to Comply?

The environmental labeling requirements apply to all producers, importers, and distributors who place textile products on the French market, regardless of its origin. This also means that non-French companies are included if they market products in France. The decree does not explicitly mention exemptions for small fashion brands or specific thresholds of company size.

Which Clothing Categories Are Included?

The Environmental Cost applies only to “produits textiles d’habillement” – clothing items made primarily of textile fibers, whether natural or synthetic, including any trims or integrated component parts.

Products made of more than 20% non-textile materials by mass are excluded. Shoes and accessories are also excluded, even when they contain textile components.

The product categories considered are the following:

1° Boxer / Briefs;

2° Underpants;

3° Socks;

4° Shirt;

5° Jeans;

6° Skirt / Dress;

7° Swimsuit;

8° Coat / Jacket;

9° Pants / Shorts;

10° Pull;

11° T-shirt / Polo.

The following textile products are currently excluded:

Second-hand products.
Products of which more than 20% of the mass is composed of materials other than textile fibers
Products for which more than 20% of the mass is composed of materials whose modelling of the contribution to the calculation of the environmental cost does not appear in the methodological notice (i.e. is not present in the list of Ecobalyse materials)
Products integrating electronic components.
Products made from Leather and accessories e.g. belts, scrunchies, cases, pouches, bags, tote bags.
Personal protective equipment unless it can be purchased directly by end consumers.

Environmental Cost Methodology and Ecobalyse

Ecobalyseis the official tool developed by the French government to calculate and communicate the environmental impact of textile products. It aims to calculate the “environmental cost” of textiles, reporting on impacts such as water consumption, greenhouse gas emissions, biodiversity damage, and microfiber pollution, using life cycle assessment (LCA).

How It Works

The tool allows users to enter basic product attributes — such as material composition, weight, place of manufacture, and processing — to generate an aggregated environmental impact score, called a “coût environnemental” (Environmental Cost), expressed in numeric points.

Ecobalyse was originally designed with three levels of assessment:

Level 1: Simplified LCA-based methodology using global-average data.
Level 2: Integrating brand-provided data from internal systems or questionnaires
Level 3: A complete, product-specific LCA using primary supply-chain dat

Currently, only Level 1, the simplified LCA-based methodology using global-average data, is required for the environmental cost calculation. Levels 2 and 3 remain under development within Ecobalyse, and it is still uncertain whether they will be implemented in the future.

Currently, Ecobalyse is only available in French. However, Carbonfact has developed a free Carbonfact’s Environmental Cost Calculator and benchmark tool, with an English interface, endorsed by Ecobalyse.

How to Calculate Environmental Cost?

The Environmental Cost must be calculated and displayed for each sales reference, which refers to a unique product colorway (référence couleur). This means that each color of a product requires its own score. The score must be based on a single representative size, as defined by the official size table for each market segment (e.g., men, women, children).

Brands cannot publish different scores for different sizes – the representative size is used as the benchmark for the entire size range of that colorway.

Step 1: Life-Cycle Assessment

Ecobalyse models the full life cycle of garments: from raw materials, through processing (spinning, textile formation, coloration and finishing, assembly), to transport and distribution, use, and end-of-life.

Step 2: Compute 16 PEF Impact Indicators

Computes all 16 Product Environmental Footprint categories. Changes to weightings under Eco-Score methodology include: freshwater ecotoxicity is double-weighted, while the two human-toxicity indicators receive zero weight.

Environmental impact categories and weights

Step 3: Normalizations and weightings

To get a single Environmental Cost score, Ecobalyse goes through two steps:

Normalization: Each impact (climate, water, toxicity, etc.) is converted into comparable “impact points.” Ecobalyse uses the same normalization factors as the European PEF method.

Weighting: Each impact is given a share of importance. Here Ecobalyse differs slightly from PEF (climate and ecotoxicity weighs heavier, see the chart).

Step 4: Additional Fashion-Specific Penalties

Beyond the PEF metrics, Ecobalyse adds two fixed-point categories to capture key apparel issues:
- Export outside of EU: penalizes used garments collected in France that are shipped abroad, instead of being reused or recycled locally.
- Microplastic shedding: assigns points based on the share of microplastic fibers each material releases during washing.

Durability Coefficient

In the Life Cycle Assessment, Ecobalyse adjusts each product’s use phase with a durability coefficient between 0.67 (low durability) and 1.45 (high durability). This coefficient depends on two main inputs:

Range breadth (50%): How many product references (SKUs) the brand sells in the same category (e.g. women’s T-shirts). A wide range signals rapid trend turnover, typical of fast fashion, and lowers the durability score. If the brand does not provide this data, Ecobalyse applies a default of 100,000 references (worst case).
Repair incentive (50%)

Based on the ratio between average repair cost and the brand’s reference sales price (retail price of the product), plus whether the brand offers a recognized repair service. If no price or repair info is available, Ecobalyse assumes no repair service and applies conservative defaults.

The resulting coefficient increases or decreases the assumed number of wears for the garment.

Higher coefficient → product lasts longer, impacts spread across more uses → lower cost per wear.
Lower coefficient → product lasts fewer wears, impacts concentrated → higher cost per wear.

Which Data Do You Need to Calculate Environmental Cost?

To generate a compliant Eco-Score, brands (or third parties) must provide product data through the Ecobalyse tool or its API.

Mandatory Parameters

The mandatory parameters in Ecobalyse are the minimum data points needed to generate an Environmental Cost score, ensuring that every product can be scored consistently, regardless of brand data availability.

Product category
Mass of the finished product
Nature & percentage of raw materials
Geographical Location of textile formation (weaving/knitting)
Geographical Location of ennoblement (finishing)
Geographical Location of confection (assembly)

Note: While it is technically mandatory to measure and provide all of these data points, when the manufacturing locations are missing, Ecobalyse will apply “India” as a conservative default value. The Eco-Score is, however, only compliant if the brand delivered primary data for all 6 mandatory data points.

Optional Parameters

Not required, but highly recommended. If left blank, Ecobalyse uses conservative defaults: it assigns “India” as the default country of production, assumes a 100k product range, 100% air transport, and sets all durability-related criteria to reflect ultra–fast fashion.

Providing real values here helps lower the score.

Remanufactured vs. new status
Number of products offered in the segment
Reference price
Company size & repair-service offering
Geographical origin of raw material sourcing
Geographical origin of spinning
Type & % printed surface (finishing)
Application of a washing process
Air-transport share
List of accessories

NOTE: If you have real data for a given parameter (say, your actual % of air freight or your true repair-service take-up), you must feed those numbers into the calculation and not use defaults.

Fixed Parameters (preset by product type; cannot be changed)

Spinning type
Yarn titration
Weaving/knitting process
Weight linkage to category
Dye type (finishing)
Manufacturing complexity
Loss rate in confection
Dormant-stock rate

These parameters are fixed at sector-average values because brand-specific data is hard to verify, their impact on the score is small, and standardizing them keeps results consistent across all products.

Why Should Fashion Brands Calculate the “Voluntary” Eco-Score?

As of one year after entry into force, any person distinct from the manufacturer/importer may calculate and communicate the environmental cost without needing the brand’s consent. “Personne physique ou morale” — NGOs, retailers, comparison websites, industry associations, journalists or even individual consultants can step in and run the official methodology to produce an Eco-Score if the brand itself hasn’t done so, provided that they have access to the mandatory parameters.

Under the AGEC law, brands must already disclose the country of origin for certain process steps and material (fiber) composition is already mandated under existing EU textile labelling regulations. This means that, in practice, third parties could obtain much of the mandatory data needed to calculate the Environmental Cost, making this scenario a realistic possibility.

This could look like:

Big e-commerce platform integrating Eco-Scores into its product listings, auto-computing scores for any brand that hasn’t published its own.
Fashion Revolution releasing its annual Fashion Impact Report and calculates missing brand scores using publicly available product data.
A journalist investigating label transparency independently calculates Eco-Scores for brands that haven’t done so.

However, for missing data, third parties will have to rely on Ecobalyse’s default parameters, which are conservative and result in higher (less favorable) Environmental Cost. This happens because third parties lack access to optional, detailed product data, such as transport modes or production processes, which only brands can provide.

Note: Multiple third-party scores for the same product can coexist on the portal.

Though not a legal requirement, this setup creates a strong incentive for brands to calculate their own scores, because:

Scores calculated by third parties will result in higher Environmental Cost in high scores.
Scores calculated by brands themselves will automatically replace third-party scores, with a maximum delay of one month.

When Is Calculating Environmental Cost Mandatory?

If your French website already displays a single environmental score (for example, a carbon footprint on product pages), it will become mandatory to display the official Environmental Cost label from October 2026. In other words, showing the Eco-Score will become mandatory whenever another standalone score is presented.

Brands are allowed to declare their eco-score on the official portal without making it public, for example, on their website or at the point of purchase. The regulation only requires prior declaration if a brand chooses to publish or otherwise communicate the score to consumers; declaration alone does not create any obligation to display the score publicly.

In practice, this allows brands to declare a score as a defensive measure, preventing third parties from publishing their own calculated version. Once declared, the score may be reused by third parties such as retailers or NGOs, but any such use must rely on the brand’s declared score rather than an externally calculated one.

What Is the Eco-Score Publishing Process?

The online portal for data submission will officially launch on September 15, 2025. Scores uploaded before that date will not be retained. It allows submissions via CSV upload, API, or manual entry, and includes delegation options for third-party representatives (e.g., consultancies or LCA experts). Improvements will be rolled out iteratively.

4 steps:

Calculate the score: Brand may run the official methodology on any medium they choose – their own software, the open-source Ecobalyse code, or the public calculator. The only duty is to follow the calculation rules.
Immediately after computing the score, the third-party must publish a data record on the government portal designated by the environment and economy ministries.
Four mandatory fields of information have to be disclosed on the portal: 1) the Environmental Cost in impact points; 2) the list of parameters & any specific data used; 3) the product reference ID and its market-launch date; 4) the calculation date, the legal status of the calculator, and the version of the methodology applied.
Once the data is on the portal, the brand/third-party may display the score wherever it informs consumers: e-commerce pages, product listings, shelf labels, apps, printed catalogues, social media, etc. The visual must follow the standard label rules.

How Do You Show the Environmental Cost on Your Labels or Online?

Display of the score includes:

Mandatory Header: Always include the words “Environmental Cost” (in the local language).
Pictogram of Impact Points: A simple icon alongside the total “points d’impact” calculated for the product.
Normalization per 100 g: Below (or beside) the total points, display the same number of points recalculated per 100 g of product mass.
Digital Display: Whenever you show the Environmental Cost on a website or app, you must include a link to the full dataset on the official portal.

Digital Display: Whenever you show the Environmental Cost on a website or app, you must include a link to the full dataset on the official portal.

Graphics: You cannot modify the official design – only scale it up or down proportionally if needed.

Minimum Size Requirements:

On a shelf label or product page, the Environmental Cost must be at least as large as the price text.
On physical packaging or hangtags, it must remain clearly legible.
In all media (print or digital), its size must match or exceed any other environmental score or label you display for the same product.

Textile Eco-Score: Updates and Revisions

The Eco-score framework allows for updates to ensure accuracy and reflect improved data:

Quarterly Updates: Brands can update their scores every three months with more precise data or corrections.
Mandatory Revisions: If the methodology or decree is modified, brands must revise their scores within 12 months to remain compliant.

This structured approach ensures that the Eco-Score reflects the most accurate and current information over time.

Methodology: French Eco-Score vs PEFCR

The French Textile Eco-Score is a simplified LCA-based method designed for consumer-facing applications. It introduces novel parameters such as emotional durability and the export of textile waste outside the EU.

The PEFCR for Apparel & Footwear, in contrast, is a more detailed framework. It is supported by the EF 3.1 database and applies the standardized EF 3.1 impact assessment method. Many of the same modeling principles used in the PEFCR also underpin parts of the French framework.

This table summarizes some key differences between the two methods. It is not exhaustive – feel free to suggest additions if you notice other relevant divergences!

How Can Carbonfact Help Your Brand?

Automated Eco-Score calculation for all products: Carbonfact imports all your data, generating Eco-Scores for all products in scope without manual work.

Compare against category benchmark products: Carbonfact’s platform allows you to see how your product compares against industry averages and decide whether to publish or improve first.

Simulate and improve your Eco-Score: Use Carbonfact’s Eco-design Tool to simulate products with differing materials and processes – so you can see and improve your score before publishing.

Push data directly to the French declaration portal: Carbonfact is integrated with Ecobalyse, so you can submit your calculated Eco-Scores directly to the French portal.

Full Overview of the EU Textile Strategy and Regulations

Lidia Lüttin — Sun, 18 Jan 2026 23:30:00 GMT

Despite recent European Union shifts toward economic competitiveness and regulatory simplification, apparel and footwear brands will face a series of binding sustainability requirements over the next few years.

Fashion Brief: ESRS E1 Climate Reporting for the CSRD

Lidia Lüttin — Sat, 17 Jan 2026 23:15:00 GMT

While the Corporate Sustainability Reporting Directive (CSRD) is now in force and first disclosures were published in 2025, the Omnibus I Simplification Package has narrowed the scope of the CSRD and delayed upcoming reporting deadlines for most fashion brands.

Overview of All Textile Extended Producer Responsibility (EPR) Laws

Lidia Lüttin — Wed, 14 Jan 2026 23:30:00 GMT

For Fashion Brands: Navigating Sustainable Textiles Labeling Globally

Lidia Lüttin — Wed, 14 Jan 2026 23:15:00 GMT

In this era of heightened environmental awareness and climate legislation, apparel and footwear brands are increasingly under the microscope when it comes to their climate and sustainability practices. To address this, nations and regions are introducing a web of intricate textile labeling laws, each with its own set of standards and regulations.