In December 2024, the United States Government Accountability Office (“GAO”) published a report detailing its findings on textile waste and the harmful effects it has on the environment.[i] This was the first time a government agency acknowledged and provided recommendations for what is considered “one of the biggest issues facing the fashion industry.” [ii] In its report, the GAO compiled research and information from academic, federal, industry, and nonprofit sources.[iii] They were all in agreement: the shift toward a fast fashion business model in the last twenty years is likely responsible for the staggering increase in textile waste.[iv]

Fast fashion encompasses a large section of the fashion industry “whose business model relies on cheap and speedy production of low quality clothing,” which is then rapidly circulated through stores in an effort to meet current trends.[v]The term first appeared in the 1990s when retail giant Zara began operating in New York and was used to describe Zara’s ambitious mission of taking a garment from the design stage to stores in only fifteen days.[vi] It did not take long for other fast fashion retailers, such as H&M, Topshop, and UNIQLO, to join the fray.[vii] The development of online shopping saw the rise of other brands that could operate on an even cheaper and faster level, like Shein and Fashion Nova.[viii] Shein, specifically, could create and have clothing ready for sale in ten days.[ix]

To meet these deadlines, fast fashion retailers are pressured to reduce their costs and speed up production, which results in cutting corners in terms of environmental welfare.[x] Fast fashion incorporates the use of cheap textiles, such as nylon and polyester, and toxic textile dyes.[xi] This, in turn, requires a considerable amount of water and energy and results in a significant emission of greenhouse gases.[xii] As is, the fashion industry holds the dubious honor of being the “second-largest consumer industry of water” while also comprising 10% of total global carbon emissions.[xiii]

In sustaining their business model, fast fashion retailers must drive consumers to purchase these garments quickly. This is not challenging to do, as consumer habits reflect how individuals are drawn to inexpensive clothing modeled off haute couture on the runway.[xiv] However, given these garments’ poor quality and susceptibility to quick wear and tear, consumers tend to discard them quickly, and the vicious cycle continues.[xv]

In the decades since, the United States has witnessed the effects of fast fashion firsthand. The GAO found a rise in textile waste volume by more than 50% between 2000 and 2018.[xvi] Approximately 11.3 million tons of textile waste end up in landfills annually.[xvii] The negative impact of fast fashion is further exacerbated when there is no unified system in place to prevent it from reaching landfills.[xviii] Unlike recyclable materials, material recovery facilities cannot process textiles since no collection infrastructure exists, and what textile sorting technology exists is limited in capacity.[xix]

As bleak as the situation may seem, the mere existence of the GAO’s report is reason alone for cautious optimism.[xx] In addition to outlining the effects and magnitude of textile waste on the country, the GAO also calls on federal entities to collaborate and address the issue through reduction and recycling efforts.[xxi] Furthermore, efforts can be undertaken by the states themselves since matters of waste disposal can be addressed at municipal, state, and federal levels.[xxii]California was one such state up for the challenge when it ratified the Responsible Textile Recovery Act of 2024 this past September.[xxiii] By doing so, the act became the first Extended Producer Responsibility (EPR) recycling program in the United States designed to address textile waste.[xxiv] An EPR program provides a framework that holds textile producers responsible for addressing the impacts textile waste has on the environment.[xxv] Although EPR programs are relatively new in the United States, they date back several decades in the European Union, where they originated.

Under California’s law, qualified apparel or textile producers will be required to join a producer responsibility organization. Once approved by the state, the organization will be required to construct a plan that covers the entire lifespan of the textile, including collection, repair, reuse, and recycling. The stringent standards this law imposes on these producers help address the issues created by fast fashion head-on. Fast fashion trends focus on producing these garments and getting them to customers in record time, with little to no consideration for what occurs after these garments have left shelves. Requiring such forward-looking plans may ultimately compel fast fashion retailers to reconsider their business practices.

Implementing a novel law of this kind could also inspire other states to take similar action. Shifting the burden to the producers of textile waste may also be easier on states that do not have the budget or technology required to overhaul or implement the infrastructure needed to address the considerable volume of textile waste currently in circulation. Furthermore, California’s law delineates penalties for producers found to be in violation of its requirements. These penalties could be allocated toward upgrading existing infrastructure. Unfortunately, there is nothing in the GAO’s report that requires federal agencies to work together to address the growing textile waste issue, be it by legislation or administrative regulation. Given that reality, it seems as though state-driven legislation is the most efficient way of addressing this issue, given the urgency needed at this time.

While it may take time to see these changes go into effect, consumers may continue to take matters into their own hands by engaging in conscientious habits by creating capsule wardrobes, renting outfits, and opting for high-quality clothing made of lower-impact materials. When discussing the ethical and environmental issues surrounding the fashion industry, British designer Vivienne Westwood succinctly said it best: “buy less, choose well, make it last.” [xxvi]

[i] See U.S. Gov’t Accountability Off., GAO-25-107165, Textile Waste: Federal Entities Should Collaborate on Reduction and Recycling Efforts (2024).

[ii] Bella Webb, The US Finally Acknowledges Textile Waste in New Report, Vogue Bus. (Dec. 18, 2024), https://www.voguebusiness.com/story/sustainability/the-us-finally-acknowledges-textile-waste-in-new-report.

[iii] See U.S. Gov’t Accountability Off., supra note i, at 23.

[iv] See id.

[v] Olivia Lai, Explainer: What Is Fast Fashion?, Earth.Org (Nov. 10, 2021), https://earth.org/what-is-fast-fashion.

[vi] See id.

[vii] See Solene Rauturier, What Is Fast Fashion and Why Is It So Bad?, Good On You (Aug. 7, 2023), https://goodonyou.eco/what-is-fast-fashion.

[viii] See id. (“These brands are known as ultra fast fashion, a recent phenomenon which is as bad as it sounds.”).

[ix] See Rashmila Maiti, The Environmental Impact of Fast Fashion, Explained, Earth.Org (Jan. 20, 2025), https://earth.org/fast-fashions-detrimental-effect-on-the-environment.

[x] See Rauturier, supra note vii.

[xi] See id. (“[The use of toxic textile dyes makes] the fashion industry the one of the largest polluters of clean water globally, right up there with agriculture.”).

[xii] See Maiti, supra note ix.

[xiii] See id. (“The fashion industry… requir[es] about 700 gallons to produce one cotton shirt and 2,000 gallons of water to produce a pair of jeans.”).

[xiv] See Lai, supra note v (“For individual consumers, it is also easier and more economic to snatch up cheap clothing that have short life spans compared to splurging on high quality, long lasting items that will very shortly fall out of popularity.”).

[xv] See id. (“This cycle of buying and discarding creates a huge environmental problem, with the world accumulating mountains of textile and clothing waste every day, most of which are not biodegradable.”).

[xvi] See Webb, supra note ii.

[xvii] See Martina Ingini, 10 Concerning Fast Fashion Waste Statistics, Earth.Org (Aug. 21, 2023), https://earth.org/statistics-about-fast-fashion-waste.

[xviii] See U.S. Gov’t Accountability Off., supra note i, at 7–8.

[xix] See id.

[xx] See Webb, supra note ii (“The most significant thing about the GAO report isn’t necessarily what it says, it’s that it exists at all. The report reinforces what many in the industry already know, but does so in a coordinated way, directed at the federal government.”).

[xxi] See U.S. Gov’t Accountability Off., supra note i, at 42 (outlining the seven recommendations the GAO made to the National Institute of Standards and Technology, the Office of Science and Technology Policy, the U.S. Department of State, the U.S. Department of Energy, the National Science Foundation, and the Environmental Protection Agency).

[xxii] See id. at 2 (“All levels of government have a role in textile waste and recycling… States and municipalities manage certain solid waste streams through coordination with EPA and other federal entities and develop and implement recycling programs.”).

[xxiii] See Danielle N. Garno & Vicky Yuan, A Closer Look at California’s Recently Passed Responsible Textile Recovery Act of 2024, Holland & Knight (Oct. 17, 2024), https://www.hklaw.com/en/insights/publications/2024/10/a-closer-look-at-californias-recently-passed-responsible.

[xxiv] See id.

[xxv] See Textile and Fiber Policy 101: Influential New Legislation You Should Be Paying Attention To, Fibershed (Nov. 2, 2023), https://fibershed.org/2023/11/02/textile-and-fiber-policy-101-influential-new-legislation-you-should-be-paying-attention-to.

[xxvi] See Madeleine Hill, How To Buy Less, Choose Well and Make it Last, Good On You (June 8, 2018), https://goodonyou.eco/how-to-buy-less-choose-well-and-make-it-last.