THREADS Sustainability and Social Responsibility Protocol

The American Apparel & Footwear Association, the Accessories Council, The Council of Fashion Designers of America, and Fashion Makes Change - and the thousands of brands and organizations we represent - are committed to working pre-competitively to achieve the highest ethical and responsible standards across our global supply chain and production practices. With supply chains that reach across the globe, our industry is at the forefront of environmental sustainability and social responsibility efforts, but brands and retailers cannot address these concerns alone. We welcome policymakers’ interest in addressing concerns regarding worker rights, environmental sustainability, chemical management, and human rights matters in global supply chains. The involvement of local and national governments, as well as supranational bodies and international organizations, has the potential to build on industry initiatives related to key concerns, establish achievable benchmarks, and catalyze widespread progress. 

Policy proposals must account for the work industry, stakeholders, and governments at every level will need to undertake to achieve the desired outcomes if they are to be effective. Enthusiasm for a desired outcome is not enough.  Poorly designed policies divert resources away from successful or promising industry initiatives and instead create barriers to real progress on environmental and social issues affecting the industry. 

To assist policymakers in ensuring their best intentions result in implementable and successful solutions, we present the THREADS Fashion Protocol. These core tenets will enable policymakers to develop practical, workable, and effective regulatory proposals to advance sustainability and social responsibility in the fashion industry. We look forward to policies that meet these criteria. 
For questions, contact Chelsea Murtha. For media inquiries, contact media@aafaglobal.org. Follow along with #THREADSProtocol and #SmartSustainability.

Transparently Developed & Enforced

Regulatory systems are complicated, and they work best when they are developed by all stakeholders in a manner that is public, that fairly accepts and responds to input, and that synthesizes that input into the regulatory regime. But transparency does not stop at the development of the regulations. Requirements need to be transparently enforced so companies know they are competing on a level playing field and the public understands and can gain confidence in the system that makes sure the regulations are doing the job they are supposed to do.

Harmonized Across Jurisdictions & Industries

Harmonizing regulations and enforcement ensures a common approach and cost-effective implementation, greatly enhancing the likelihood that the regulations will have their desired effect. Even regulations passed in identical format by different jurisdictions can be interpreted and enforced differently, leading to confusion and undermining public trust. Further, fashion is not the only industry driving towards these goals. While some regulations may need to be tailored for specific industries, there may be opportunities to share good regulatory practices and initiatives with other similarly situated sectors. 

Realistic Timelines

Implementation and enforcement timelines that account for and reflect the level of systems change required affect a policy’s likelihood of achieving its objectives. Enforcement agencies, regulated industries, and the public all need a clear understanding of when particular provisions will take effect and time to prepare to understand and adjust to new requirements.  New regulatory regimes require significant investments in systems, education, and compliance. Timelines need to build in periods that allow for those investments to occur and for products manufactured prior to the implementation of those provisions to be sold. 

Enforceable

Policymakers must consider and understand how enforcement will take place if they are to achieve their aims. Government agencies should not be put in a position of having to enforce regulations without proper resources, education, or direction. Businesses need clear guardrails, particularly at the enforcement stage, and an understanding of how regulators will measure success. Regulations should lay out a clear, achievable pathway for compliant behavior. Outside stakeholders monitoring regulations also need to know how the government will itself measure success.

Adjustable

Regulations must be allowed to evolve. Periodic reviews that account for new developments, technologies, new approaches, and new thinking, as well as involving input from all stakeholders in a transparent manner, should be built into regulatory regimes. Static regulations that lack mechanisms allowing them to respond to new realities or fix implementation problems quickly outlive their usefulness. Even worse, they can end up retarding the progress they were designed to foster. 

Designed for Success

Regulatory regimes are intended to foster compliant behavior. Establishing incentives and support for compliance efforts is necessary to enable industry to make desired changes and inspire further progress. Resources dedicated to needed research or the development of systems and best practices that ease compliance efforts are examples of positive ways policymakers can enable industry to meet new requirements. Requirements perceived as overly punitive create pathways for reduction in economic activity, as brands and retailers exit businesses in which the risk outweighs the financial reward, whereas leading with a goal of industry success benefits everyone by lessening failure rates, easing burdens for enforcing agencies, and achieving the desired outcomes.    

Science-Based

Precision matters. At the same time, if that precision is not grounded in science, the goals of the regulations may be unachievable. Moreover, regulations that are not based on facts or grounded in science are difficult to explain – to enforcers, to the regulated community, or to the public at large. Such regulations can create confusion, frustration, and resentment, all of which impedes the collaboration necessary to meaningfully address social and sustainability challenges.