24 Feb What’s ‘Green’ in London is ‘Illegal’ in Brussels. We’re not managing sustainability, we’re managing a global vocabulary crisis
Why fragmented regulation create a maze of certifications, standards and claims, each tailored to different priorities and agendas
Hello and welcome back to Frayed Not!
Our mission is to remind you that change doesn’t need to be perfect, just possible!
Whether you are a sustainability advocate or sustainability specialist, we are here to support those that carry the real weight of change so sustainability moves from strategy to execution.
Today we’re covering:
- Why the fragmented standards landscape leads to more chaos and confusion in a volatile economy
- How ambiguous regulations and harsh penalties, without the right guidance or infrastructure, create incentives for brands to be less transparent
- What unexpected consequence can regulations create, pushing brands to perform sustainability, not progress
Are you ready to build change?
CONTEXT
We are at a tipping point. When regulations move faster than the infrastructure to support them, we don’t get more transparency, we get more lawyers. In a volatile economy, sustainability has moved from an era of ‘Intentionality’ to one of ‘Reactivity’.
And it was needed. Sustainable practices have been put off by brands for more than a decade. What felt like a ‘we’ll worry about that later’, now lands as ‘overdue’. But what happens when there is a mismatch between the foundation that can support the change and the pressure of compliance? We’re building on quicksand.
There is no single rulebook for sustainability in fashion, yet. There never has been. What once used to be a creative industry, crafting product for expression of one’s identity, displaying taste or making a statement, is now acting like a mathematical formula. A landscape of competing frameworks, fibre-specific standards, brand pledges that measure numbers. A brand can hold a valid certification for its materials, pass a factory audit, publish a net zero commitment, and still have no coherent picture of its actual impact across the full supply chain.
These are stories from my time in the industry. Real life examples of how, when humans are cornered, they will find shortcuts.
The wrong certification
- The factory was certified, but for a different recycled fibre to what the brand was using. A tiny, technical distinction that made an entire shipment non-compliant, proving that in a volatile market, the brand’s lack of technical education is a supplier’s most exploitable asset
- The supplier wasn’t necessarily a villain. They were a business in survival mode, pressured by brands to cut margins until the only way to protect their livelihood was to find a “technical workaround” in the certification paperwork
The travel miles
- Circularity doesn’t mean the shape of a business model is a circle. It has to account for the geography of the supply chain
- If the recycled product travels 5 countries (from where the recycled pellets are produced, to where they are turned into yarn, then made into fabric, then made into garments, then shipped to sell, potentially being collected back or not), manufacturing virgin material between two neighbouring countries will ironically have a lower carbon footprint
- But because regulations value the LABEL of the recycled content, over the REALITY of logistics, brands are incentivized to perform sustainability rather than achieve it
FACTS and STATS
Let me be clear. Regulations are needed. But the gaps mentioned above have not emerged from neglect. They are the accumulated result of how regulations have evolved and been enforced. Standards bodies, NGOs, industry coalitions, trade bodies, and regulators have each built frameworks that reflect their own priorities, methodologies, and stakeholder interests. Some focus on fibre. Some focus on facility. Some focus on carbon. Some focus on social rights. Very few were designed to work together across different trade regions, which leaves brands selling across different countries with a commercial operating nightmare.
The result is a maze. Brands navigating it are not making strategic sustainability decisions. They are making compliance decisions, asking which certification is most recognisable, which one their buyers require, and which one is achievable within the current budget and timeline. What makes this difficult is the regulation is accelerating.
The EU Green Claims Directive, the Corporate Sustainability Reporting Directive, extended producer responsibility schemes, and mandatory due diligence legislation are all moving at different speeds toward different requirements. Brands that have built their sustainability credentials around voluntary standards are now discovering that what satisfied a retailer buyer in 2021 may not satisfy a regulator in 2026. The ground is shifting, but there is no map that shows where it is shifting to.
IMPACT
The average apparel brand now navigates dozens of overlapping sustainability frameworks simultaneously. Fibre standards, facility compliance, social schemes, climate disclosure, each measuring different parameters using incompatible methodologies. It’s not clear which sustainable effort will hold up to regulatory scrutiny. When the framework is this fragmented, even honest sustainability investment can end up in the wrong place.
Enter, greenhushing. Where brands that make sustainable efforts are now terrified of penalties and they choose not to disclose sustainability at all. As mentioned initially, humans are wired to find shortcuts.
For internal sustainability teams, the fragmented landscape creates a resource problem as much as a strategic one. Time and budget spent on ensuring multiple certifications, trade deals between countries in which the product is sold, reporting incompatible frameworks whilst ensuring profitable margin for both themselves and the supply chain becomes unmanageable when investment in the number of resource these teams have is minimal.
Now, when all of this reaches the consumer, they are left with the confusion of discerning between a verified standard and a brand’s marketing language. When the industry cannot align on what sustainability means or how to measure it, that incoherence travels all the way to the shelf. Consumers are not confused because they don’t pay attention. They are confused because the information they are given is overwhelming and ambiguous. Until voluntary standards, regulatory requirements, and brand-level reporting are better aligned, that will not change.
PROS and CONS
Pros
- Regulatory pressure is forcing long-overdue consolidation: The EU Green Claims Directive and Corporate Sustainability Reporting Directive are pushing brands toward standardised, substantiated, and auditable reporting. That pressure is uncomfortable for businesses that built their credentials on voluntary frameworks, but it is also an opportunity. Brands that build genuine measurement capability now are positioning themselves ahead of a requirement that is coming regardless
- Fragmentation reveals where the real gaps are: The fact that a brand can be certified in one area whilst having no visibility in another is useful information. It shows exactly where the system is not joined up and where investment would produce the most meaningful change
Cons
- The current system rewards performance over progress: When labels and messaging are at the forefront of change, rather than supporting and funding better incentives for a fairer supply chain, change becomes performative. Until the standards landscape aligns more closely with regulatory requirements, genuine progress will remain harder to distinguish from well-branded compliance
- Multiple certifications do not add up to a coherent story: A brand holding six different certifications across six different dimensions of sustainability cannot necessarily combine them into a clear, credible picture of overall impact. Each standard was designed in isolation. Together they do not tell a cohesive story, either to the regulator or the consumer. The sum is often less than the parts
SYSTEMS THINKING
The fragmented standards landscape is not a collection of individual problems that can be fixed one certification at a time. The ambiguity of the guidance and conflicting timelines make commerciality without funding difficult to achieve. If the amount of funding and support given to the AI infrastructure would be attributed to sustainability, brands operating within the system would be able to comply faster and build the new business models required to adhere to regulations.
- Consumers demand better, but cheaper products
- Brands struggle to meet the price demand, putting pressure on the factories and cutting their margins
- Factories, mostly underpaid as it is, find shortcuts to meet the demand, at the cost of: their own livelihoods or the damage of the environment through processes that cause contamination
- As a results of the processes, we either have:
- Polluted water (from the garment dyes disposed in water streams, microplastic when laundering, affecting aquatic life and the food chain)
- Air pollution (due to heavy machinery used in manufacturing, leading to weather pattern instability; hence the wildfires, heavy snows and floods in the last few years)
- Contaminated land (unused material or unsold stock being burnt in landfills)
Every part of this broken system feeds into the next. Only government rules have the power to break that cycle. This isn’t because the rules are perfect, it’s because they change the incentives, in a way that voluntary efforts never can.
But the more important shift is internal. Brands that treat the fragmented landscape as an organisational problem, rather than an external one to navigate, are asking a different kind of question. Not “which certifications do we need?” but “what does genuine impact look like across our supply chain, and how do we build the internal systems to measure, report on, and improve it?”
That question cannot be answered by a standards body. It has to be answered inside the organisation. And it requires design, sourcing, finance, and sustainability to be looking at the same picture at the same time, which is not how most brands currently operate.
Regulatory alignment will help, but it will take time and the frameworks that emerge will still require brands to build internal coherence that the external landscape cannot provide for them. The organisations that understand this are not waiting for the rules to settle. They are building the capability now.
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Cited sources:
- European Commission. EU Green Claims Directive. 2024
- European Commission. Corporate Sustainability Reporting Directive. 2024
- Good On You. The Problem with Eco Labels in Fashion. 2024
- Fashion Revolution. Fashion Transparency Index. 2024
- OECD. Sustainability Certifications in the Garment and Footwear Sector. 2025
