This report ranks 200 of the world’s largest fashion brands on disclosure of their climate and energy-related policies, practices and impacts in their own operations & supply chains.
Fashion Revolution works towards a vision of a fashion industry that conserves and restores the environment and values people over growth and profit. The Rana Plaza disaster in Bangladesh instigated the creation of Fashion Revolution and spurred millions to join our call for greater industry transparency and accountability in the fashion industry. Fashion Revolution has become the world’s largest fashion activism movement, mobilising citizens, industry and policy makers through research, education and advocacy work.
The issues in the fashion industry never fall on any single person or brand. That’s why we focus on using our voices to transform the entire system. With systemic and structural change, the fashion industry can lift millions of people out of poverty and provide decent and dignified livelihoods. It can conserve and restore our living planet. It can bring people together and be a great source of joy, creativity and expression for individuals and communities.
The content of this publication can in no way be taken to reflect the views of any of the funders of Fashion Revolution. © Fashion Revolution CIC 2025. All rights reserved. This document is not to be copied or adapted without written permission from Fashion Revolution CIC.
This report was researched and written by Fashion Revolution CIC. www.fashionrevolution.org
Liv Simpliciano
Ciara Barry
Delphine Williot
Isabella Luglio
Ysabl Dobles
Designed by Molly Porteous
Published in September 2025
JAN ROSENOW, PROFESSOR OF ENERGY & CLIMATE POLICY, UNIVERSITY OF OXFORD
We all use textiles every single day: think of the clothes we wear, the sofas we sit on, and the beds we sleep in. But few people know that making those textiles is based on burning vast amounts of fossil fuels. That has to fundamentally change in a net-zero world. But how?
One of the most promising levers for phasing out fossil fuels in the textiles industry is the electrification of processes that currently use fossil fuels. Processes such as dyeing, printing, drying, washing and bleaching require large quantities of heat, and that heat can be provided with technologies such as heat pumps, electric boilers and heat batteries using electricity from clean power sources like solar and wind. This stops the use of fossil fuels and reduces carbon emissions but also improves air quality and reduces noise. Clean heat solutions therefore have the potential to improve worker safety and address overheating in factories. This means that electrification is not just a climate solution; it can also contribute to safer working environments and cleaner air for surrounding communities.
The potential for electrification of process heat in the textiles industry is very large: up to 100% of process heat used in the textiles sector can technically be provided with existing technologies. This is because the temperatures typically required in the textiles sector are comparably low and top out around 250 degrees Celsius. The main challenge is to move from potential to practice.
Historically, companies decided to use fossil fuels because they were readily available and often cheaper than using electricity. This puts the onus on governments to act and ensure that electrification is cost-competitive through clever taxation of energy and financial support programmes. More and more countries have started to understand this and changed policy. Companies that decide to transition would then see economic benefits rather than paying a premium.
But companies also have their work cut out: There are already technologies out there that can compete with fossil fuels. But it requires a clear strategy, a closer look at the options and a roadmap for a transition away from fossil fuels. Some corporates made inroads already and
have demonstrated what is possible. Leading by example rather than being dragged towards cleaner production pays off: Businesses along the supply chain and consumers pay increasing attention to the climate impact of the products they buy. Those companies that can demonstrate cleaner production methods may be able to charge a green premium for their products. Although not applicable to the fashion industry yet, new policies and regulations, such as the European Union’s Carbon Border Adjustment Mechanism (CBAM), make it less and less attractive to import carbon-intensive products as those face higher carbon taxes. This emerging policy landscape underscores the urgency for fashion to decarbonise heat and power now, before regulation and market forces leave no room for inaction.
Electrification is not just a climate solution, it can also contribute to safer working environments and cleaner air for surrounding communities
Finally, in a world of poly-crises and geopolitical tensions, relying on fossil fuel imports that are subject to increasingly volatile market prices is a risky strategy.
Electrification of the textiles sector offers a path towards more energy security and less dependency on imported fuels, the price of which is outside the control of individual countries or companies. We see more and more companies across sectors investing in on-site renewable electricity generation or contracting with renewable energy generators directly. Without similar investment, fashion’s reliance on fossil-powered heat will leave suppliers exposed to rising costs and supply disruptions.
Industrial electrification presents a tremendous opportunity for the textile sector. It is now up to policymakers and companies to make it a reality – let’s make it fashionable to electrify fashion.
24/7 HOURLY MATCHING
24/7 hourly matching ensures every hour of electricity usage is paired with locally or regionally sourced carbonfree generation, precisely aligning consumption with renewable production to reduce emissions.
ANNUAL MATCHING
Annual matching involves aligning a company’s yearly electricity use with renewable sources, but it may not fully decarbonise the grid due to timing mismatches between renewable availability and actual consumption, leading to lower emission reductions compared to hourly matching.
CARBON FOOTPRINT
This measures the total amount of carbon dioxide (CO2) emissions produced by an individual, organisation, or activity, typically through the burning of fossil fuels. It helps gauge the impact of these activities on climate change.
CLEAN HEAT
The use of truly renewable sources like wind and solar to meet manufacturing’s thermal energy demand, through solutions such as electric boilers and heat pumps.
CLIMATE ADAPTATION
Adaptation involves adjusting practices, processes, and systems to reduce the adverse impacts of the climate crisis. For example, developing supply chains that are resilient to climate hazards, such as installing flood defences in a factory.
CLIMATE MITIGATION
Mitigation refers to actions taken to reduce or prevent the emission of greenhouse gas. This can include measures like switching to renewable energy and improving energy efficiency
DEGROWTH
Degrowth challenges the paradigm of unlimited economic growth by advocating for a socially just and ecologically sustainable society. It promotes reducing global consumption and production, emphasising well-being over material accumulation and advocating for equitable distribution of resources.
ENERGY PROCUREMENT
How brands and retailers buy and report their energy — through tools like Renewable Energy Credits, Power Purchase Agreements, or onsite generation — which determines whether their renewable energy strategies deliver real carbon reductions.
GLOBAL MAJORITY
Refers to most of the population of the world that live in what is often referred to as ‘developing countries’ or ‘the Global South’. It recentres Black, Indigenous and People of Colour (BIPOC) as the majority, moving away from the minoritisation experienced in white supremacist and colonial history and culture.
GLOBAL MINORITY
Refers to the smaller population of the world that live in wealthier nations, often described as ‘the West’ or ‘the Global North’.
The backbone of electricity systems, responsible for transporting power from generation sources to end-users like garment factories. Some grids run on clean energy like wind and solar, some depend on dirty fossil fuels or a mix of both. Upgrading and expanding grids is vital to meet demand and power the clean energy transition.
A fair shift to a low-carbon fashion industry that puts garment workers at the centre of decisions about brand decarbonisation efforts that impact them. Workers, through their unions, co-design solutions that protect their jobs, wages, health, and communities. This includes the right to organise, bargain collectively, and engage in genuine dialogue with brands and suppliers. Brands must share the costs of decarbonisation instead of pushing them onto workers or suppliers, ensure living wages, and invest in protections suited to local contexts so no one is left behind.
Carbon offsetting is when companies compensate for their carbon emissions by investing in external projects that reduce or sequester GHGs, such as reforestation or renewable energy. While it allows companies to claim ‘carbon neutrality’, it often does not address the emissions produced directly within their own operations and can be controversial due to issues like doublecounting and the effectiveness of the projects.
CARBON PRICE
The cost assigned to each unit of carbon dioxide or its equivalent emissions, either through a carbon tax or the price of emission permits in carbon trading schemes. This price varies across different carbon trading systems globally and reflects the effort needed to mitigate climate change impacts.
RENEWABLE ELECTRICITY
Renewable electricity is power generated from sustainable sources like wind, solar, and hydro, which naturally replenish and have minimal environmental impact.
RENEWABLE ENERGY
Renewable energy comes from natural sources that are replenished faster than they are consumed, like sunlight and wind. It produces significantly lower emissions than fossil fuels, making it essential for combating climate change. However, not all renewable sources are entirely green or clean if they generate some emissions or environmental harm.
SCOPE 1 EMISSIONS
Scope 1 emissions are direct greenhouse gas emissions from sources that are owned or controlled by an organisation, such as emissions from fuel combustion in company-owned vehicles and facilities.
SCOPE 2 EMISSIONS
Scope 2 emissions are indirect greenhouse gas emissions from the generation of purchased electricity, steam, heat, or cooling consumed by the organisation.
SCOPE 3 EMISSIONS
Scope 3 emissions are all other indirect greenhouse gas emissions that occur in the value chain of the organisation, including both upstream (related to purchased goods and services) and downstream (related to sold goods and services) emissions.
THERMAL ENERGY
Heat used in factories to dye, wash, and dry clothes. In fashion, it is often generated by burning fossil fuels on site.
Fashion’s climate targets are falling dangerously out of step with reality. Instead of cutting emissions at the pace science demands, billion-dollar fashion brands are dragging their feet, withholding even the most basic data, all while emissions continue to soar.
Overproduction, fuelled by the industry’s pursuit of profit, is sacrificing a livable planet for garments too often treated as disposable — a throwaway culture that treats our shared home the same way.
The pressures of overproduction come into focus in Tier 2 processing facilities, hotspots of emissions and worker risk. These are the dye houses, laundries, and finishing mills where the fabrics of our clothes are made. Here, meeting demand means burning vast amounts of fossil fuels to generate heat for fabric processing. The result is toxic air inside factories and surrounding communities, overheated workplaces, and the single largest share of fashion’s emissions, alongside the industry’s toughest decarbonisation challenge.
Fashion’s climate future will be decided by how the industry tackles heat: ending its reliance on fossil fuels in manufacturing and scaling up clean heat — renewable, fossil-free energy for manufacturing processes.
Fashion’s climate future will be decided by how the industry tackles heat
The technologies needed to replace fossil fuels in production already exist (like heat pumps and electric boilers) and have the potential to offer a twofold benefit: cutting emissions at scale while addressing workplace and environmental harms. Electrification could lower indoor factory temperatures, reduce workers’ exposure to heat stress, and clear the air, contributing to safer conditions inside factories and in surrounding communities.
But technology alone is not enough. The climate crisis is also an inequality crisis: brands’ business models in the Global Minority drive emissions, while garment workers in the Global Majority face unsafe heat, polluted air, and unstable livelihoods on poverty wages. A Just Transition means workers and suppliers must not be left behind — brands must share the costs of decarbonisation, enable living wages, and engage in genuine social dialogue with unions and suppliers. Without this, clean heat risks replicating the same extractive patterns that created the crisis.
Underpinning the urgency of the transition is the reality that progress is stalling. After nearly a decade of pressure, transparency on suppliers’ list has plateaued. Without visibility of where production takes place, brands cannot map emissions hotspots or plan collective investments in clean heat. This roadblock exposes the limits of voluntary action — and comes just as EU Omnibus proposals threaten to weaken corporate accountability by limiting due diligence to Tier 1 suppliers and making climate transition plans optional. The potential rollbacks will keep Tier 2 — the greatest emissions hotspot — in the shadows, slowing electrification, leaving workers exposed and derailing climate progress.
The technologies needed to replace fossil fuels in production already exist and have the potential to cut emissions at scale while addressing workplace and environmental harms
The fashion industry has the chance to electrify much of its low-temperature processing now. Paired with renewable energy, this is low-hanging fruit for decarbonisation. If fashion fails to seize the clean heat opportunity, the industry risks losing credibility in a world moving beyond fossil fuels — and compromising the health, safety, and dignity of the people who make our clothes.
This report proposes a framework for industry adoption created by Fashion Revolution and climate campaigning organisation Action Speaks Louder. ‘ Clean Heat for Cool Work ’ is a scalable solution to address fossilpowered heat on two fronts: (1) continuous, low-cost monitoring and disclosure of factory heat and humidity data to help protect workers from unsafe heat now, and (2) investment in clean heat technologies like electric boilers and heat pumps powered by renewables to replace fossil fuels. Together, these tracks demonstrate how adaptation (protecting workers from heat stress and harmful air pollution) and mitigation (cutting fossil fuel use and greenhouse gas emissions) can reinforce each other when advanced together by brands who commit to paying their fair share. By acting now, fashion can lead an industrial decarbonisation revolution that delivers both climate action and safer conditions for the people who make our clothes.
Fashion fails to act on its most urgent decarbonisation opportunity: clean heat.
Fashion’s reliance on fossil-fuelled heat in dyeing, finishing, and processing facilities is the single largest source of supply chain emissions — and it is where urgent action is needed. Proven technologies like heat pumps and electric boilers are already available to replace fossil fuels, making this the industry’s most pressing and actionable decarbonisation challenge. Unlike heavy industry, fashion faces relatively low technical barriers to electrification. Research consistently shows that heat needs up to 150°C can already be electrified today using existing technologies and that process heat rarely exceeds 250°C, meaning the industry has the potential to move entirely away from fossil fuels. And yet, a mere 6% of brands disclose any efforts to electrify high-heat processes. Furthermore, only 10% of brands disclose supply chain renewable electricity targets, and just 6% disclose broader renewable energy targets, a serious shortfall. Without electrification, renewable targets risk being weak and ineffective as brands may lock in biomass or other stopgap solutions. Even if electricity is renewable, heating, cooling, and steam can still run on coal or gas. Decarbonisation therefore requires a comprehensive plan covering both power and heat. By failing to act, fashion’s billion-dollar brands are not only slowing progress — they are overlooking the industry’s clearest opportunity to cut emissions rapidly.
short: none include purchased steam, leaving coal embedded in
Less than a quarter of Big Fashion 1 brands (18%) disclose coal phase-out targets at the processing level, and the failure to cover purchased steam shows a lack of ambition. Many factories buy steam from nearby coalfired combined heat and power plants or district heating systems — meaning they can claim to be “coal-free” on-site while still relying on coal indirectly. Including purchased steam in a coal phase-out target closes this major loophole. By covering purchased steam, brands ensure their commitments tackle all coal-derived heat in production — not just what’s burned on their own premises – driving real emissions cuts and preventing coal use from being outsourced. Without closing this gap, coal can disappear from factory boilers yet still power production through external suppliers — keeping fashion locked into fossil fuels. Crucially, if multiple brands demand action on purchased steam, it could shift the equation entirely: collective pressure would create the leverage needed to push industrial zones to invest in cleaner infrastructure. While individual brands often claim they lack influence as “one buyer among dozens”, coordinated demand and financing are exactly what is required to unlock this transition.
Show us the money: Almost no brands disclose how they are funding decarbonisation or suppliers’ rising costs.
Brands set ambitious supply chain decarbonisation targets, but most stop short of showing how they support suppliers to deliver them, making financing the transition a guessing game. Only 6% disclose upfront (CapEx) support — for example supporting suppliers to replace coal-powered boilers with electric ones or heat pumps — and just 2% disclose help with ongoing (OpEx) costs such as renewable electricity bills or equipment maintenance. Without brand financing, suppliers cannot absorb the million-dollar costs of switching from coal to clean heat, leaving climate targets hollow.
This creates a chicken-and-egg problem: suppliers are reluctant to electrify if the grids remain fossil-fuel heavy, while governments and utilities hesitate to invest in renewable infrastructure without clear industrial demand. Brands sit at the centre of this deadlock. On-site action is important, but without cleaner grids, electrified equipment may still run on coal or gas. This is why grid advocacy is essential — especially in countries where fashion is one of the largest export industries. When brands signal collective demand, they can help unlock renewable investment at the level required to drive the transition forward.
Breaking this cycle means brands must act on three fronts simultaneously: financing supplier electrification (e.g. replacing coal boilers with electric heat pumps), investing in or securing long-term power purchase agreements with renewable projects in production hubs, and using their influence to support national renewable energy scale-up. Doing this through a Just Transition lens — sharing costs, protecting jobs, and ensuring no community is left behind — will not only accelerate decarbonisation but also strengthen supply chain resilience.
1
60% of brands disclose energy sourcing in their own operations, but just 11% in supply chains, where it matters most. Many lean on Renewable Energy Credits (RECs) which mask fossil fuel use, making climate action for many brands an exercise in accounting, not accountability. Accounting fixes cannot replace true decarbonisation. To make this shift, brands must power supply chains with real-time renewable energy — not just on paper. Unlike annual or monthly accounting, 24/7 matching ensures consumption is met with clean generation each hour, sending a strong demand signal to decarbonise grids and cut reliance on fossil fuels. Yet with no brand disclosing this approach, the industry is lagging behind this urgent priority.
Billion-dollar brands fail to leverage their purchasing power for decarbonisation.
Fashion demands suppliers decarbonise, yet most brands do little to enable the structural change needed to make that transition possible. Expecting suppliers to decarbonise without advocating for structural change is self-defeating — it undermines brands’ own climate commitments. Only 7% of brands disclose evidence of renewable energy political advocacy in garment-producing countries, and just 2% report outcomes. Even fewer (6%) disclose direct investment in grid-scale renewable energy projects. Given their influence, brands have both an imperative and an opportunity to help shape enabling environments — from policies that let factories sell unused renewable power back to the grid (net-metering) and lower import duties on green technologies, to enabling power purchase agreements and phasing out coal. Supporting grid decarbonisation does not just help suppliers meet targets; it raises the floor for all industries and positions fashion to lead in driving collective climate progress.
Publicly-listed companies make up the majority (59%) of brands scoring zero on traceability — exposing a glaring accountability gap in ESG oversight.
Despite being answerable to shareholders and subject to sustainability reporting frameworks, many of the world’s biggest listed fashion companies are failing at the most basic level of supply chain transparency. This lack of disclosure prevents investors and stakeholders from assessing whether brands are phasing out coal, electrifying factories, or protecting workers from mounting heat risks. In short, fashion’s transparency plateau has become a direct climate action roadblock: without supplier visibility, credible decarbonisation is impossible.
Unprepared
for the future: almost half of big brands fail to disclose climate risks to their operations and supply chains.
Fashion supply chains are already being disrupted by the climate crisis , from floods and droughts to escalating heatwaves. For major brands and retailers, understanding these environmental risks and their financial implications is essential to future-proofing business. Yet, a little more than half (57%) of brands provide details of their climaterelated risks.
Beyond the moral imperative to do so, the fashion industry must gain an in-depth understanding of climate-related risks which in turn would support their strategy to reduce their greenhouse gas emissions (mitigation) and build resilient supply chains able to navigate the impacts of the climate crisis such as extreme heat and floods (adaptation). Climate risks directly affect productivity, supply chain stability, and operational costs — factors that are material to investors. Without this data, business resilience and investor confidence is undermined as they are left unable to assess risks that fall squarely within their fiduciary duty to consider. At a time when environmental and human rights due diligence rules are being weakened globally, visibility of these risks is more important than ever: not only to protect workers and supply chains, but to give investors the information they need to make sound financial decisions.
Big
Fashion needs a temperature check: the industry’s hottest climate risk is going unmeasured, with workers’ health and livelihoods on the line.
0% of brands disclose factory data on heat and humidity levels (also known as Wet Bulb Globe TemperatureWBGT), even as extreme temperatures leave garment workers fainting, falling ill, and losing income as productivity drops. Heat stress is not only a human rights issue but also a financially material risk for investors: economy wide, by 2030, global productivity losses are projected to reach $2.4 trillion annually, equivalent to 80 million jobs lost . For the fashion industry, the impact is acute. Cornell’s Hot Air report shows that in garment manufacturing hubs like Karachi and Phnom Penh, workers already face ~112–115 unsafe WBGT days each year — nearly one-third of the year in extreme heat, with serious consequences for both wellbeing and output. Public WBGT disclosure would give unions the evidence to bargain for protections, inform brands of the costs of adaptation like cooling systems, provide investors with a decision-useful metric to assess financial and operational risks, and unlock adaptation tools like parametric insurance. Without it, heat protections cannot be embedded into binding mechanisms like the International Accord, leaving workers unfairly exposed.
CEO pay continues to soar — up 23.5% on average for the 25 highest-paid US fashion executives — while only 15% of brands disclose whether bonuses are linked to absolute carbon reduction, and most of those tie just 10% of pay to climate performance. A slightly higher share (20%) discloses supplier incentives for decarbonisation, but power imbalances mean responsibility still falls on suppliers rather than brands. Investors, too, are missing a crucial opportunity: just 7% of brands disclose an internal carbon price, leaving fashion far behind other sectors in embedding climate accountability into financial decision-making. In addition, with the rise of climate skeptics politics, we are seeing a rollback on environmental legislation globally, with legislation such as the Corporate Sustainability Due Diligence Directive (CSDDD) being heavily watered down to remove the obligation to put climate transition plans into effect while the Trump administration wants to eliminate regulation for greenhouse gases – ultimately supporting the short term financial interests of big lobbies over people and the planet.
Just over half of brands (55%) disclose having a ScienceBased Targets initiative (SBTi)-verified target that covers Scopes 1–3. However, fewer than a third (29%) provide evidence that they have actually reduced their greenhouse gas (GHG) emissions from the baseline. With only 20% of brands disclosing that they consult suppliers on their climate targets and just 9% disclose co-creating climate adaptation solutions, brands’ failure to work in genuine partnership is one factor stalling climate progress. Cocreating strategies with suppliers — who are experts in their own local context — would make decarbonisation and adaptation plans stronger and supply chains more resilient to climate shocks. Yet, very few brands are transparent about taking this approach.
Just a quarter of brands at the manufacturing level (23%) and 19% at the processing level disclose supply chain ownership. Even more telling is that among brands disclosing this information, levels of ownership are minimal: more than half report owning no manufacturing (62%) or processing (68%) facilities.
Brands with higher ownership levels are better placed to invest in renewable energy, pilot clean heat technologies, and coordinate adaptation strategies because they offer greater stability. By contrast, brands that rely on short-term contracts with opaque supply chains lack both visibility and leverage to deliver decarbonisation. Achieving real progress will require brands to move beyond extractive, short-term profit supply chain models and actively invest in stable, longer-term supplier partnerships. These relationships create the trust and stability required to share investment, accelerate the renewable energy transition, and deliver on broader climate goals.
• Electrify heat at scale. Replace coal, oil, and gas boilers with proven technologies like heat pumps and electric boilers, starting with pilot projects in brands’ own supply chains— even on fossil-heavy grids — to cut emissions today, build evidence across geographies, and de-risk wider adoption. Pair this with time-bound supply chain targets for 100% renewable power, full public disclosure, and prioritisation of truly renewable sources like wind and solar — not biomass or other stopgap fuels.
• Break the chicken-and-egg cycle. Finance supplier electrification, secure renewable power through Purchase Power Agreements (PPAs) or direct investment in new renewable projects, and use brand influence to advocate and co-fund systemic reforms that decarbonise factories and national grids.
• Implement continuous WBGT monitoring. Brands must roll out low-cost, continuous monitoring of heat and humidity in supplier factories — with workers and unions leading the process. This simple measure generates decision-useful data, ensures accuracy, and creates credible baselines for adaptation tools like parametric insurance.
• Guarantee fair and stable purchasing. Provide long-term, stable orders and fair contracts that give suppliers the security to invest in decarbonisation — instead of pushing costs down the chain.
• Enable living wages. Ensure workers and their unions can collectively bargain for living wages — the most effective adaptation strategy — giving communities resilience to withstand shocks and the agency to shape their own futures.
• Put worker-led due diligence at the centre of decarbonisation. Uphold freedom of association and collective bargaining, embed worker-led monitoring and meaningful social dialogue, and support protections designed with local communities — backed by binding agreements and jointly governed funds — so no one is left behind in the transition.
• Go beyond compliance. Align business practices with international climate and human rights standards, and adopt risk-based due diligence across all tiers — with priority on high-risk sites like dyehouses and finishing plants — ensuring workers and unions are central to defining and monitoring the most salient risks.
• Pressure brands on heat risk. Press for continuous disclosure of factory heat and humidity levels (WBGT), with worker-led monitoring to ensure accuracy. This low-cost measure generates decision-useful data on productivity losses that are financially material, while enabling unions to bargain for safer conditions and unlocking adaptation tools like parametric insurance.
• Make clean heat a transition indicator. Use shareholder leverage to push brands to electrify all thermal processes with proven technologies like heat pumps and electric boilers.
• De-risk supplier investment. Use credit guarantees and blended finance tools to unlock capital for clean heat and renewable energy in fashion’s supply chains.
• Use this research to inform your activism, not your consumption. Scrutinise brand claims and hold them to account.
• Demand worker protections. Push brands to disclose data on factory heat and humidity levels (WBGT) and address unsafe heat facing the people who make our clothes, and ensure that unions and communities have a central role in defining and addressing unsafe heat.
• Stay informed on policymaking. Understand how supply chain accountability, renewable energy access, and worker protections are shaped by regulatory debates — and scrutinise corporate lobbying that seeks to weaken them.
• JOURNALISTS
Platform workers’ voices. Expose the gap between brand claims and on-the-ground realities, spotlight workers facing heat stress and unsafe conditions, and report on lobbying efforts (e.g. Omnibus, CSDDD rollbacks) that undermine climate and labour rights.
• ACADEMICS
Provide independent evidence. Generate peerreviewed data on clean heat adoption, worker health impacts, and emissions reductions; translate complex technical findings into accessible insights for policymakers, investors, and the public; and ensure research actively incorporates worker and community perspectives on due diligence priorities.
• CIVIL SOCIETY
Advocate, mobilise and hold to account. Amplify unions and grassroots organisations, monitor whether brand commitments (coal phase-out, renewable targets, Just Transition plans) deliver in practice, and scrutinise government and corporate actions that shape regulatory frameworks. Leverage advocacy and campaigning strengths to ensure clean heat remains a priority — highlighting its dual potential to deliver major emissions reductions and protect workers from unsafe heat. Push to expand the International Accord to explicitly cover unsafe workplace heat, with worker-led monitoring of WBGT and factory conditions — particularly for brands with seats on the Accord steering committee.
This year, What Fuels Fashion? will aim to:
• Expose fashion’s dependence on fossil-fuelled process heat.
• Spotlight clean, electrified heat as the industry’s most urgently needed response to decarbonisation.
• Demonstrate that industrial electrification has the potential to deliver a dual solution: reducing greenhouse gas emissions (mitigation) and improving working conditions on the factory floor by protecting workers from heat stress and reduce harmful air pollution inside factories and in surrounding communities (adaptation).
• Push the world’s biggest fashion brands to phase out coal in supply chains and invest in scalable, electrified alternatives like heat pumps and electric boilers.
• Provide policymakers, investors, trade unions, and campaigners with the data needed to demand brand accountability and drive industrial electrification where it matters most — at the energy-intensive processing stage.
• Highlight heat stress as a frontline human rights and climate risk – recognising it as defined by workers themselves - and show that a credible Just Transition depends on worker-and communityled due diligence, underpinned by Freedom of Association and meaningful social dialogue.
• Raise public awareness of clean heat as fashion’s overlooked climate opportunity and build collective pressure so that brands act now, rather than waiting for fully decarbonised grids.
• Drive scrutiny, accountability, and systemic change by ranking 200 billion-dollar fashion brands on their transparency, revealing who is leading and who is lagging behind the clean heat transition.
Fashion Revolution began researching transparency eight years ago. Since then, the climate crisis has intensified and so has the cost of inaction. Today, the industry’s lack of transparency on climate and energy use is a direct barrier to decarbonisation and accountability.
Without visibility into how factories are powered, how much coal is being burned, or what conditions workers are experiencing on overheated factory floors, brands cannot credibly phase out fossil fuels, electrify supply chains, or deliver a Just Transition. Clean heat and industrial electrification are possible, but without disclosure, progress cannot be measured and responsibility cannot be enforced.
Despite mounting public pressure, much of the global fashion industry remains opaque. This opacity conceals continued reliance on coal and other fuels (like gas and biomass), obstructs accountability, and delays both mitigation and adaptation – from phasing out fossil fuels to protecting workers from dangerous heat stress.
Transparency is not a radical demand – it is the bare minimum. It is the first step toward climate accountability and a Just Transition. With transparent data, workers, communities, policymakers, investors, and civil society can hold fashion’s biggest brands accountable and push them to act at the speed and scale the climate crisis demands.
We have updated the scope of brands included in our research through a strategic and data-led process.
Since our first edition, we have focused on evaluating fashion brands with an annual turnover of at least USD $400 million, measured at either the brand level or parent company level. For privately held brands, we have relied on the best available public data to estimate turnover.
In late 2024, we contacted the 250 brands2 included in the previous edition of WFF, asking for updated information on:
• Annual turnover (at brand or group level), with publicly available sources if possible.
• If reporting at group level, whether the group is primarily focused on apparel retail.
• For diversified companies (e.g. supermarkets), a breakdown of how much turnover is attributable to apparel, footwear, garments and/or textiles. Example: “Total turnover: £2bn, ofwhich approximately£500m (25%) is apparel.”
We recognise that privately held brands may not wish to disclose exact figures. In these cases, we encouraged brands to share a turnover range (e.g. £100m–£500m) or confirm whether turnover exceeds £5 billion. Where no data was provided, we used public sources to assess eligibility.
After reviewing brand responses and conducting our own research, we refined our focus for the 2025 edition. This year, we are focusing on 200 of the world’s largest fashion brands with a turnover of USD$1 billion. Our updated scope prioritises brands that are primarily apparel retailers, or where apparel makes up a significant proportion of overall revenue.
This shift allows us to:
• Prioritise brands with the greatest resources and responsibility to lead on climate and energy transition.
• Streamline our analysis to focus where the impact can be greatest.
• Dedicate more time to deep-dive research and sharper advocacy.
Together,
the 200 brands now in scope have a combined estimated turnover of approximately USD $2.7 trillion.3
By narrowing our lens, we strengthen our ability to hold the industry’s most powerful players accountable and push for urgent action where it is needed most.
Our research focuses on what brands choose to publicly disclose. Public self-disclosure matters because it creates accountability: data that is transparent, specific, and accessible can be used by workers, unions, policymakers, investors, and civil society to drive change on climate and human rights in fashion’s supply chains.
2 Fashion Revolution contacted all brands previously in scope of our research. Where brands did not respond, we relied on the most recent publicly available data to assess their eligibility for inclusion. Some brands contacted Fashion Revolution after the research began, including s.Oliver and Tom Tailor, who both fall below the USD $1bn threshold and therefore outside the formal scope. Both brands were invited and chose to voluntarily participate in the consultation and review process.
3 To calculate this figure, we summed the publicly available annual turnover data for each brand. If multiple brands belonged to the same parent company, we counted the parent company’s turnover only once to avoid double counting. All turnover figures in non-USD currencies were converted to USD using the United Nations Operational Rates from July 2025.
Public self-disclosure
What Fuels Fashion? evaluates what brands publicly self-disclose about their decarbonisation efforts in their operations and supply chain.
Points are awarded only for publicly disclosed information/data on major brands’ policies, procedures, performance, and progress on decarbonisation efforts across the value chain.
Up-to-date information
Most of our research indicators are timesensitive, and we only consider disclosure that has been published January 2022 or later.
Accepted Sources for Public Disclosure
Public self-disclosure
What Fuels Fashion? does not measure a brand’s decarbonisation impacts; it measures public disclosure.
Verification of claims made by brands and retailers is beyond the scope of this research. However, stakeholders are encouraged to use our research to hold brands accountable for their claims.
Up-to-date information
This does not apply to disclosure that is not timesensitive (e.g. we will allow relevant policies and commitments published before this date if they still apply and are publicly disclosed).
We award points only for information/data that has been publicly disclosed on the brand or parent company’s own website (or directly linked to it).
We review information which is publicly available from one of the following places:
• On the brand or parent company’s website
• Sustainability microsites (provided there is a direct web link to it from the main brand or parent company website)
• In annual reports or annual sustainability reports published on the brand or parent company website
• In any other documents which are publicly available and can be downloaded freely from the brands’ or parent company’s websites
• Via external, third-party websites, but only when there is a direct web link from the brand or parent company’s website to the third-party website where specific disclosures can be found
We do not count the following information sources:
• A third-party website or document where there is no web link from the brand’s own website, including press articles
• Clothing labels and hang tags on products
• In-store or other physical locations
• Smartphone apps
• Social media channels
• Information provided to us by a fashion brand that cannot be found on the brand’s website
What Fuels Fashion? does not measure ethics or sustainability. A brand can score highly on transparency of their decarbonisation efforts, but this does not mean they are ethical or sustainable.
We do not endorse any brand in the research or suggest that consumers shop at specific brands based on their ranking. This is not a shopping guide.
The challenge of measuring climate plans through transparency alone
Transparency remains a central pillar of our theory of change, and we stand by the principle that no data is data — the absence of disclosure is itself a meaningful signal. But we also recognise the limitations of assessing complex climate transition plans through transparency alone.
Our methodology is designed to raise ambition by spotlighting emerging issues — such as 24/7 hourly matching and industrial electrification — and by rewarding detailed, comparable disclosures. Yet, nuance can sometimes be lost. Because we assess transparency in binary terms (disclosed or not disclosed), some brands may be marked down for failing to report on practices they do not actually use. Without clear public disclosure, however, we cannot tell the difference between a brand that genuinely does not use a practice and one that is simply choosing not to be transparent.
This tension underscores both the importance and the limits of public disclosure. Transparency remains the foundation of accountability but it cannot substitute for a deeper evaluation of the integrity of brand transition plans. For this, we look to complementary work from organisations like Action Speaks Louder, Stand.earth , NewClimate Institute , and others.
For this second edition of What Fuels Fashion? , some findings are comparable year-on-year, others are not. We refined our scope to focus on 200 of the world’s largest fashion brands, each with an estimated annual turnover of over USD $1 billion. As a result, some data from 2024 has been recalculated to reflect only those same 200 brands, ensuring a more accurate and consistent comparison where possible. In cases where year-on-year comparisons are valid, this is clearly stated in the report.
Additionally, we introduced new indicators to strengthen the analysis. For this reason, not all data points can be compared directly with those published in 2024. Unless otherwise specified, all percentages in the 2025 edition should be understood as out of the 200 brands reviewed this year.
As an example , 34% of brands reviewed disclosed a time-bound and measurable commitment to decarbonisation whereas less, 32% of brands, disclosed progress against their decarbonisation targets. This indicates that fewer brands report on their progress than those who state they have such targets. It does not mean that of the 34% of brands who have a decarbonisation target, 32% of them disclose progress against their target.
SUPPLY CHAIN EMISSIONS SPLIT
For apparel brands, scope 1 emissions (with Science Based Targets) typically account for 1% of their total emissions, while Scope 3 represents around 96%.
Data from Apparel Impact Institute
Average score across the 200 brands reviewed in 2025
In this subsection, we examine who in the company is accountable for the brand’s climate performance and impacts. We check if brands publish information on the percentage of CEO and executive-level pay and incentives tied to achieving absolute carbon reduction across the entire value chain. We also assess whether suppliers’ incentives, such as long-term contracts, increased order sizes, price premiums, and reduced audits, are tied to decarbonisation improvements.
Additionally, we are looking for whether brands disclose an internal price on carbon and what that price is.
Here we assess what brands are doing to address overproduction. We looked specifically at:
• Public disclosure on how many items were produced in the reporting period
• Brands’ public commitment to degrowth
This subsection focuses on whether brands are publishing supplier lists, focusing on the level of detail provided at three different levels:
1. The factories where clothes are made, often referred to as the first-tier or tier 1 manufacturers — in other words, the facilities with which brands have a direct relationship and typically do the cutting, sewing and final trims of products;
2. The processing facilities further down the supply chain — knitting, weaving and spinning mills, wet processing, embroidery, printing and finishing, dye-houses, tanneries and laundries;
3. The suppliers of raw materials — primary materials such as fibres, hides, rubber, chemical and metals.
We check whether brands are sharing the following information:
• Name of parent company
• Address of the facility
• Type of products/services supplied
• If the list is in machine-readable format (csv, json, xls)
• If the list is contributed to the Open Supply Hub platform
This year, we also included a new indicator to help assess the level of brand ownership of their manufacturers and processing suppliers.
Fashion’s governance model remains profit-first, sidelining climate action even as climate risks escalate.
This past year has been particularly difficult for the fashion industry. Economic pressures have forced brands to make staff cuts , climate disruptions caused by rising temperatures and flooding continue to destabilise supply chains, and the luxury market is showing signs of strain amid global economic uncertainty and geopolitical tensions. The looming threat of Trump’s proposed tariffs adds further instability, with major implications for global supply chains. Yet, even against this backdrop, fashion CEOs’ pay continues to rise with an average increase of 23.5% for the 25 highest-paid CEOs in American fashion.
Fashion CEOs’ pay continues to rise, with an average increase of 23.5%
This imbalance is particularly striking given that only 15% of brands disclose the percentage of executive bonus or pay tied to achieving absolute carbon reduction. Of those 30 brands, about half disclose that just 10% of the bonus is tied to this target – a low figure considering fashion executives’ significant responsibility to achieve climate targets but also their urgent moral duty to act in the face of a devastating planetary crisis.
Fewer brands (20%) disclose supplier incentives tied to decarbonisation, compared to last year’s 24%. This backslide is concerning: incentives like long-term contracts, increased orders, price premiums, and fewer audits are critical to spur the investments needed in supply chains. However, to accelerate changes at the scale and speed needed, incentives and accountability systems must be built at brand AND supplier level. Given existing power imbalances between major brands and their suppliers, a Just Transition requires shifting the financial responsibility for decarbonisation back to major brands and their executives to work hand in hand with suppliers and drive meaningful decarbonisation across supply chains.
Major fashion brands and retailers must also embed climate accountability directly into their financial decision-making. One of the clearest ways to do this is by adopting an internal carbon price (ICP).
Setting an ICP is a crucial step in a brand’s climate strategy. It assigns a monetary value to greenhouse gas emissions across the value chain, creating clear pressure points to decarbonise. According to CDP, the most commonly cited reasons to set an ICP are:
• Driving low-carbon investment
• Improving energy efficiency
• Shifting internal behaviour
• Identifying new low-carbon opportunities
• Navigating GHG regulations
• Stress-testing investments
From an investor perspective, this tool is particularly useful: it helps define financial materiality to assess and manage carbon-related risks within operations and supply chains while helping investors understand how effective the application of a carbon price is to meet a company’s climate goals.
The way an ICP is designed also reveals a company’s approach to climate risk. According to Plan A, there are three commonly used approaches to set up an ICP:
• Shadow price: A company assigns a notional cost to each ton of greenhouse gas emissions when weighing up investment decisions. This helps compare the cost and benefit of different reduction strategies, but no money is transferred as part of this approach.
• Internal carbon fee or charge: The company sets a price on its emissions and charges itself accordingly. The money collected is then reinvested into energy efficiency or emissions reduction projects, helping manage climate-related risks and meet reduction targets.
• Implicit carbon price: The price is calculated based on the organisation’s cost to implement emissions reduction projects. This is then applied to where GHG emissions are emitted within the business. Companies can strategically use an implicit carbon price to allocate funds across the business.
These approaches signal the level of a brand’s ambition: while a shadow price is often used as a starting point, internal fees or charges directly generate funds for decarbonisation. Yet, only 7% of major fashion brands and retailers disclose their ICP. This lack of transparency signals that major brands are lagging far behind other sectors. For example, nearly 50% of the world’s largest 500 companies reported having an ICP in place in 2021 and 44% of chemical companies , according to KPMG.
Within the 14 brands disclosing their ICP, the price ranges from $10 to $108, with European companies such as JD Sports, LVMH and Puma setting higher ICPs compared to their Australian or American counterparts. It is interesting to note that while companies like H&M use a shadow price to define their ICP, luxury companies like LVMH and Burberry use a fee mechanism to invest in decarbonisation projects. Nevertheless, despite the sector’s significant carbon footprint and contribution to the climate crisis, this lack of disclosure may suggest that most major brands and retailers are failing to future proof their business against climate risks.
Setting an internal carbon price assigns a monetary value to greenhouse gas emissions, creating clear pressure points to decarbonise.
Higher carbon prices reported by Europeanheadquartered brands could reflect anticipation of upcoming carbon pricing legislation, including the EU’s Carbon Border Adjustment Mechanism (CBAM) — which applies a levy on carbon-intensive imports, though textiles are not yet included — as well as the EU Emissions Trading Scheme (ETS), a cap-and-trade system that sets an annual emissions cap and allows companies to buy and sell allowances.
In contrast, companies that adopt higher, more realistic ICPs signal to investors that they are preparing for a lowcarbon economy, aligning financial planning with climate targets, and creating dedicated funds for decarbonisation projects in their supply chains.
Without knowing where production takes place, brands cannot identify which factories are still running on coal, which regions are most exposed to climate risks like flooding or extreme heat, or where electrification and clean heat investments would have the greatest impact. Supply chain visibility is therefore the first step in phasing out fossil fuels, scaling industrial electrification, and protecting workers on the frontlines of the climate crisis.
“ The PRI welcomes Fashion Revolution’s efforts to drive systemic progress in the fashion sector by advancing transparency and accountability across global supply chains. The expansion of global fashion supply chains has heightened their complexity and opacity, making it more difficult for investors to assess material risks linked to climate, governance, and human rights issues in the sector. Current disclosures fall short in demonstrating how executive incentives, financial strategies, and supplier support align with credible decarbonisation pathways. Investors can play an important role here, by engaging companies towards adopting credible transition plans, strengthening supplier accountability, and ensuring board-level oversight. They can also steer capital allocation towards supply chain decarbonisation and due diligence initiatives. Taken together, these actions can drive greater transparency and resilience across the sector and its value chain, helping to ensure that risks are managed responsibly while unlocking long-term value for businesses, workers, and communities.
Soh-Won Kim Specialist, Stewardship, Social Issues and Human Rights at Principles for Responsible Investment (PRI)
The fashion industry has reached a transparency plateau and it is a major climate roadblock.
Supply chain traceability has been central to Fashion Revolution’s mission from the very beginning. Since launching the #WhoMadeMyClothes campaign, we have challenged the fashion industry’s reliance on opaque, extractive supply chains built on the labour and resources of women and marginalised communities.
After nearly a decade of incremental progress, the disclosure levels of supplier lists is now stalling: 53% of brands disclose their manufacturers, 35% disclose processing facilities, and only 7% disclose raw material suppliers. These figures have barely shifted in recent years, revealing the limits of voluntary action.
Just over half (53%) of brands now disclose their finished goods facilities, a baseline level of transparency that has taken us nine years of persistent effort to reach. This plateau now poses a direct barrier to decarbonisation, highlighting the limits of voluntary action and reinforcing what we have long observed: a significant proportion of major fashion brands clearly will not disclose unless compelled by legally binding regulation.
After nearly a decade of incremental progress, the disclosure levels of supplier lists is now stalling
That is why Fashion Revolution has campaigned consistently for robust European legislation on corporate accountability — to hold major fashion brands accountable for the human rights and environmental impacts in their operations and supply chains.
For example, through the Good Clothes, Fair Pay European Citizens’ Initiative — led by Fashion Revolution and the largest ever campaign on living wages and collective bargaining in the fashion industry — we worked with garment worker trade unions, NGOs and allies to strengthen the Corporate Sustainability Due Diligence Directive (CSDDD). As part of the campaign, we jointly drafted a legal proposal addressing gaps in the directive on living wages and collective bargaining rights, critical to realising garment workers’ top demand: fair pay.
The Omnibus risks reversing advances on accountability that civil society, trade unions and worker organisations fought to secure in the CSDDD. Instead of raising ambition to meet the urgency of climate breakdown and workers’ demands, the the European Commission and Council are seeking to dilute core provisions and weaken accountability.
In February 2025, the European Commission proposed an Omnibus Simplification package to amend the Corporate Sustainability Reporting Directive (CSRD), CSDDD and the EU Taxonomy. Framed as cutting “administrative burden,” the proposal copies verbatim many demands of corporate lobby groups .
In June 2025, the Council adopted its negotiating position, in some cases going even further. The Council’s negotiating mandate widens the rollbacks, including raising thresholds for which companies are covered, delaying application by an additional year, and softening obligations around climate plans and due diligence.
The Omnibus will soon enter trilogues — closed-door talks between the European Commission, Parliament and Council. These negotiations, with little transparency or consultation, will decide whether the EU keeps meaningful accountability laws or locks in deregulation. Civil society groups, trade unions and human rights organisations have issued joint statement highlighting concerns that the Omnibus risks weakening accountability and exposes the proposal as a deregulatory package that guts due diligence, weakens accountability, and puts corporate interests ahead of human rights and climate action.
The most concerning changes
Although details are still shifting with differing proposals among the Commission and the Council, several potential rollbacks are clear and highly relevant to fashion supply chains:
• Climate transition plans made optional. The obligation to put plans into effect has been removed. The Council further dilutes ambition from “best efforts” aligned with 1.5°C to “reasonable efforts” that merely “contribute.”
• Civil liability weakened. Responsibility is left to Member States, representative actions by NGOs and trade unions are removed, and EU courts could be required to apply foreign law. This drastically limits victims’ access to justice.
• Due diligence cut to Tier-1 suppliers. Companies would only need to assess harms caused by their direct business partners. Further down the chain, action is required only if they hold vague “plausible” or “reasonably available” information.
• Monitoring delayed. Reviews of due diligence effectiveness fall from every year to once every five years, or only when measures are “no longer adequate.”
• Stakeholder voices excluded. NGOs, unions, human rights defenders and consumer groups are no longer counted as “directly affected” stakeholders.
• Sanctions diluted. Removing the 5% turnover cap risks symbolic penalties and competition between Member States to set the lowest bar.
Why this matters for clean heat in fashion supply chains
For fashion, these proposed changes would reduce accountability at exactly the point where it is most needed:
• Climate plans on paper = no action. Without enforceable implementation, transition plans risk becoming PR documents instead of investment drivers.
• Tier-1 only is a fatal flaw. If oversight stops at cutmake-trim workshops, the real hotspots of emissions and worker risk — dyehouses, printing and finishing units — will continue burning coal and fossil fuels unchecked. A proportionate, risk-based approach is needed: one that directs scrutiny and investment to where the risks are greatest, rather than limiting accountability to the most visible part of the chain.
• Coal phase-out stalls. These processing plants are the biggest users of coal and unreported steam. Without risk-based duties across the full chain, there is no push for electrification or renewable heat where it matters.
• Five-year monitoring hides risks. Energy use and worker heat exposure change year by year; long cycles mean regulators and investors lose visibility.
• Silencing unions and NGOs. Excluding those most able to flag problems cuts off information from the ground.
• Delay in application of the CSDDD – delay in accountability and action. The Council is now also suggesting delaying the application of the law to Jul 2029, despite the urgency to mitigate risks in supply chains.
The result is predictable: brands will do the minimum the law requires, workers will remain exposed to unsafe heat conditions, and the clean-heat transition will stall.
Limiting accountability to Tier-1 suppliers misses the real problem. Without knowing where production takes place, brands cannot map emissions hotspots, identify which factories still burn coal, or plan collective investments in decarbonisation and electrification. Nor can they address the mounting climate risks workers face, from heat stress on factory floors to droughts, floods and storms disrupting production. For this reason, the disclosure of supplier lists – from direct manufacturing down to raw material sources – is fundamental. Only a risk-based approach across the full supply chain can channel investment into clean heat where it is most urgently needed.
Finally, the mention of the CSDDD negatively affecting US businesses is also not new, as US-based lobbying groups were reportedly instrumental in the reopening of the CSDDD. This, in conjunction with the Trump administration wanting to eliminate regulation for greenhouse gases , once again places corporate interests ahead of human rights and climate action.
Amidst the regulatory backslide and the plateau in brand disclosure of supplier lists, there can be cause for optimism. The Global Reporting Initiative (GRI) is finalising the first-ever Sector Standard for Textiles and Apparel , which, once approved and adopted, will recommend companies disclose information about their suppliers, including names, site locations, parent companies, the types of products or services offered, the percentage of significant suppliers at each tier, the share of business volume they represent, and the methodologies used to identify them. If any of these disclosures are considered not relevant, companies will be expected to provide a reason for the omission, offering insight into why critical data remains withheld. These recommendations will apply to all textile and apparel companies reporting under the GRI, the world’s most widely used sustainability reporting standard, adopted by over 14,000 organisations in more than 100 countries. By aligning with our methodology, the new Standard could raise the floor for supply chain transparency worldwide, embedding supplier disclosure into a global reporting framework and amplifying calls for stronger regulation.
Fashion Revolution was selected as one of 21 international experts appointed by the Global Sustainability Standards Board to join the GRI Working Group. Representing civil society, labour, business, and investment sectors from across all regions, the group is responsible for shaping the content of the Standard between 2024 and 2026. Our representative brought critical insights from Fashion Revolution’s nearly ten years of research experience on transparency to the group, ensuring the standard responds to the sector’s most urgent environmental and social challenges.
Last year, despite not having a dedicated indicator, we observed that key brands with partial or full ownership of their supply chain scored higher, particularly those in sportswear and luxury, where long-term relationships with specialised suppliers are common. To explore this further, two new indicators were introduced this year to assess the extent to which Big Fashion brands disclose ownership of their manufacturing and processing facilities.
The data reveals that most brands either do not own production facilities or fail to disclose this information. Only 23% of brands disclose ownership information for manufacturing facilities, and just 19% do so for processing level – where the greatest decarbonisation challenges lie.
Vertical integration or concentrated purchasing power may give brands greater visibility, leverage and stronger transparency on climate issues.
Even more telling is that among brands disclosing this information, levels of ownership are minimal: more than half report owning no manufacturing (62%) or processing (68%) facilities.
The exceptions are concentrated in the intimates, sportswear, and luxury sectors, where higher ownership correlates with stronger performance overall. Of the brands disclosing this information, they own the following percentage of their supply chain: Fruit of the Loom and Russell Athletic (85%), Tezenis (71%), Calzedonia (68%), Intimissimi (97%), Hanes (70%), and Hermès (55%) 4. Most of these brands also rank among the top performers in this year’s research, suggesting that vertical integration or concentrated purchasing power may give brands greater visibility and leverage and with it, stronger transparency on climate issues. Other industries, like tech, show what’s possible: 95% of Apple’s suppliers — over 320 companies covering nearly all of its manufacturing spend — have pledged to power Apple production with 100% renewable electricity by 2030 .
Brands with higher ownership levels are typically better placed to invest in renewable energy, pilot clean heat technologies, and coordinate adaptation strategies because they offer greater stability. By contrast, brands that rely on short-term contracts with opaque supply chains lack both visibility and leverage to deliver decarbonisation where it matters.
For the majority of brands going back to an increased ownership level may be unlikely. However, an investment in stable, longer term partnerships is vital for progress, even outside of ownership. Achieving real progress will require brands to move beyond extractive, short-term profit supply chain models and actively invest in stable, longer-term supplier partnerships. These relationships create the trust and stability required to share investment, accelerate the renewable energy transition and deliver on broader climate goals.
Voluntary frameworks aim to raise corporate accountability standards. However, our findings reveal that many publicly-listed fashion companies — who are answerable to shareholders and often subject to ESG reporting frameworks — are failing at the most basic level of supply chain transparency. Out of the 200 companies assessed, 136 are publicly listed and 64 are privately owned. Although public companies make up most of the sample, they also represent the majority of the worst performers: of the 90 brands scoring zero on traceability, 53 (59%) are publicly listed while 37 (41%) are privately owned.
Investors must demand that publiclylisted fashion companies disclose supplier lists as a baseline requirement
This exposes not only a regulatory gap but also a critical accountability gap in investor oversight. Investors appear to be missing a crucial opportunity to use their influence to demand even the most basic transparency standards. This failure matters for climate action. Without visibility into where production happens, investors and other stakeholders cannot assess whether companies are phasing out coal, electrifying factories, or addressing worker heat stress. A lack of traceability makes it impossible to evaluate material climate risks or to channel finance into credible decarbonisation.
In short, this is a glaring gap in ESG oversight: Investors, particularly those who claim alignment with sustainable finance and ethical governance, are overlooking a fundamental building block of climate accountability. To close this gap, investors must demand that publicly-listed fashion companies disclose supplier lists as a baseline requirement — without it, any claim of alignment with climate or social goals rings hollow.
Aeropostale
AJIO
ANTA
Anthropologie
Aritzia
Armani
BCBGMAXAZRIA
Beanpole
Belle
Bershka
Billabong
Bosideng
Brunello Cucinelli
Buckle
Burberry
Burlington
Carolina Herrera
CAROLL
CELINE
Champion
Chanel
Chico’s
Cortefiel
Decathlon
Deichmann
Diesel
Dillards
Dior
DKNY
Dolce & Gabbana
DSW
Eddie Bauer
El Corte Inglés
Express
Falabella
Famous Footwear
Fashion Nova
Fila
Foot Locker
Forever21
Foschini
Free People
Heilan Home
Hudson’s Bay
Jil Sander
Kohl’s
La Redoute
Lands’ End
LC Waikiki
LL Bean
Louis Vuitton
Marc Jacobs
Marni
Massimo Dutti
Max
Max Mara
Moncler
Monoprix
MRP
New Yorker
Nine West
Pull&Bear
Quiksilver
Reebok
Reliance Trends
REVOLVE
Ross Dress for Less
Roxy
Saks Fifth Avenue
Semir
Shimamura
Skechers
Smart Bazaar
Splash
Sports Direct
Steve Madden
Stradivarius
Takko
Ted Baker
The Children’s Place
TJ Maxx
Tod’s
TOPVALU COLLECTION
Tory Burch
Truworths
Urban Outfitters
Van Heusen
Walmart
Youngor
Zara
Discloses quantity of products produced annually
Discloses a commitment to degrowth
Overproduction is fashion’s most visible climate impact — but with 91% of brands failing to disclose volumes, few are willing to be held accountable.
Overproduction is fashion’s business model. It is a systemic problem at the heart of the industry, driving labour exploitation, environmental destruction and perpetuating colonial forms of extraction. The sector thrives on creating desire, fuelling consumption, and chasing endless growth — on a planet with finite resources. This equation doesn’t add up.
The sector thrives on creating desire, fuelling consumption, and chasing endless growth
Only 9% of brands in our research disclose their annual production volumes. Across the 17 brands that disclose this information, that’s a staggering 4.3 billion 5 items produced per year. To put that in perspective, with a global population of about 8 billion, that’s more than one item for every two people on the planet — from just 17 brands alone. The true scale of overproduction is likely far greater than even these staggering numbers suggest. Transparency of production volumes is critical to addressing this deeply rooted overproduction problem.
Brand
Calzedonia
Fendi
Gildan
GUESS
Hanes
Intimissimi
Kmart Australia
Kontoor Group (Lee and Wrangler)
Mango
OVS
s.Oliver
Tezenis
Tom Tailor
VF Corporation (The North Face, Timberland & Vans)
Disclosed number of products produced during the annual reporting period 92,380,000 1,277,500,000 1,600,000,000
New research from the Apparel Impact Institute found that in 2023, emissions from the apparel sector increased by 7.5% compared to the previous year – equivalent to 944 million tonnes. The primary reason for this increase in emissions? The growth in polyester fibre production. Polyester, the world’s most produced fibre , is derived from petrochemicals, making it inherently tied to the climate crisis. But the connection goes beyond raw materials composition as already stated across this report. Producing fabric and garment uses huge amounts of energy – from processing to transport. When these materials end up as waste, all of that energy is lost, and the emissions generated in the process have been released for nothing – and will continue to cause environmental impact throughout its lifecycle.
At Fashion Revolution, we define overproduction as making more clothes and textiles than people need – creating surplus stock that is discarded, destroyed, or simply left sitting in wardrobes. By this definition, “producing to demand” is not a solution. Our position is clear: we need to make less.
With only one brand publicly committing to reduce the number of new garments produced each year, the industry is sending a clear message: it has no intention of confronting its deeply unsustainable business model.
A recent study exploring possible future trajectories for world development within planetary boundaries warns that, under current trends and policies, we will see worsening outcomes in all but one of the Earth’s planetary boundaries by 2050. Even as we globally approach multiple tipping points, fashion continues to equate progress with exponential growth in production and consumption.
Among the 200 billion-dollar brands assessed in this report, only one — Paris, a brand under Chilean conglomerate Cencosud — made an explicit commitment to degrowth. In their Sustainability Roadmap , they: “made commitmentsto reducethe amount ofclothing we produce underourown brands, design and market garmentswith durabilityattributes, increase our customers’consumption ofsecond-hand clothing, and reintegrate into production cyclesthe materials obtained atthe end ofa garment’s useful life.”
It is telling—and alarming—that this was the only explicit reference to degrowth found in our research. Degrowth is the principle of reducing production and consumption in line with planetary boundaries while improving human well-being. Those who have gained most from decades of resource exploitation, particularly major brands in the Global Minority, must lead the way in cutting consumption and addressing climate impacts.
This concept challenges the GDP-driven growth model, which measures ‘progress’ without distinguishing between value-creating activities and those causing environmental or social harm. It calls for a fair and planned reduction in production and consumption, alongside a fundamental rethink of how brands fuel demand through endless marketing and promotions.
The industry has no intention of confronting its deeply unsustainable business model
A degrowth pathway demands rebalancing power in the industry: prioritising garment workers’ rights, ensuring living wages, distributing wealth more fairly and rejecting any approach that shifts the cost of change onto garment workers.
Continuing with business-as-usual will lead us further into dangerous territory.
We cannot shop our way out of the climate crisis but ambitious policy shifts can still limit the extent of the damage if action is bold, swift, and global.
As stated in the Global Tipping Points Conference Statement 2025 :
“Thewindowforpreventingthese cascading climate dynamics is rapidlyclosing, demanding immediate, unprecedented actionfrom policymakersworldwide— especiallyfrom leaders at COP30.This is a human rights and planetaryhealth imperative, and ultimately, a matterofsurvival.”
Tackling fashion’s overproduction crisis requires more than voluntary pledges, it demands structural changes that make excessive production financially and operationally unsustainable. This is where legislation and control mechanisms come in.
Extended Producer Responsibility (EPR) and the concept of Targeted Producer Responsibility (TPR), for example, aim to manage fashion waste and disincentivise mass overproduction by holding brands accountable for the social and environmental impacts of products throughout their lifecycle. For deeper analysis on this, see pg. 39 of our 2024 What Fuels Fashion? Report .
However, legislation can also carry risks of unintended consequences when poorly designed. An example is France’s Anti-Waste and Circular Economy Law, which bans the destruction of unsold goods. While designed to curb waste, this policy has in practice benefitted some fast fashion brands. Instead of reducing production, brands can now offload surplus into second-hand markets or donation schemes , often receiving tax rebates in the process. This means they can maintain overproduction while profiting from the tax benefits—a loophole that risks entrenching the very business model the law intended to challenge. In waste-receiving countries, this “solution” still floods markets with excess clothing, undermining local economies and straining waste systems.
Overproduction is not confined to ultra-fast fashion.
The OR Foundation estimates that around 15 million used garments flood Ghana’s Kantamanto Market every week, overwhelming local economies and waste systems. Without mandatory transparency on production volumes, these flows remain largely invisible to the public, enabling companies to maintain overproduction while profiting from the image and fiscal benefits of “donation”. Far from dismantling the overproduction model, this dynamic risks entrenching it.
Another example is France’s Anti–Fast Fashion Law, passed in June 2025. The bill will require fast fashion brands to disclose environmental impact of their products, displaying an eco - score for each item, covering carbon emissions, resource usage, and recyclability. Brands with lower performance scores face heightened taxes or penalties—up to €10 per item, or 50% of its pretax price. It will also ban advertising of ultra-fast fashion goods and impose sanctions on influencers promoting these types of products.
While this is a significant regulatory step intended to discourage unsustainable overproduction and consumption, its scope remains limited. It differentiates between “ultra” and “regular” fast fashion, exempting many European brands from the advertising ban and the highest surcharges.
It is also important to note that part of the political appeal of this legislation — passed with 337 votes in favour and just one opposed — lies in its protectionist dimension for European and French fashion brands. This aspect appeals to politicians and their electorates, making the law as much about safeguarding domestic industry as it is about environmental reform.
Overproduction is not confined to ultra-fast fashion. Traditional fast fashion brands, luxury labels, and sportswear giants also rely on high-volume, rapidturnover models, with luxury brands often driving trends that others mass-reproduce at scale. Narrow enforcement and protectionist exemptions risk turning real structural problems into symbolic targets.
The necessity to produce less is undeniable. This means that all business models reliant on mass-selling, which drive overproduction, need to be overhauled.
Decarbonisation is the back bone of this year’s assessment, carrying the greatest weight in the methodology at 41% of a brand’s overall score. The weighting of this section is proportional to the urgency of the climate crisis.
In this section, we evaluate brand transparency across three subsections: Decarbonisation, Energy Consumption and Greenhouse Gas (GHG) Footprint; from setting timebound targets aligned with a 1.5°C pathway, to reporting progress against a clear base year, to disclosing energy use, electrification strategies, coal phase-outs, and full Scope 1–3 footprints.
In 2025, we strengthened our methodology to close loopholes. Progress is now measured against base-year emissions, not just year-on-year changes, exposing whether brands are truly cutting emissions or simply shifting the maths. Intensity-based targets, while widely used, are not enough. A brand’s footprint can still rise as long as emissions increase more slowly than revenue. For example, a brand could double its revenue while increasing its emissions by 20% — and still claim success against an intensity target, even though its overall footprint is higher.
On paper the numbers may improve, but the atmosphere won’t. This is a loophole, not leadership.
What’s needed are absolute emissions reductions backed by transition-specific alignment targets, clear, sectorrelevant milestones (see list below) that show how brands will actually get there. Carbon credits, renewable energy certificates, or offsetting schemes cannot substitute for real decarbonisation. To deliver genuine progress, companies must tackle the unique transitions tied to their business model. The NewClimate Institute identifies four levers specific to the fashion industry that together cover up to 85% of fashion’s Scope 3 emissions:
• Electrifying Tier 1–2 production processes
• Switching to renewable energy in Tier 1–3
• Reducing overproduction and shifting business models
• Using lower-GHG alternative fibres
Taken together, these measures represent fashion’s clearest pathway to climate alignment — but only if brands move beyond accounting tricks and into realworld emissions cuts. Our analysis focuses on the first two – electrification and renewable energy – because these directly address fossil fuel use in supply chains, where the bulk of fashion’s emissions occur.
Thermal Energy
Heat used in factories to dye, wash and dry clothes. In fashion, it is often generated by burning fossil fuels on-site.
Clean Heat
The use of truly renewable sources like wind and solar to meet manufacturing’s thermal energy demand, through solutions such as electric boilers and heat pumps.
Electrification
Replacing technologies that burn fossil fuels (like coal, oil, or gas) with electric alternatives powered by renewable energy (like wind and solar).
Anchoring this section is the fact that the path to decarbonisation will be won or lost by how fashion tackles heat: phasing out the burning of fossil fuels in manufacturing and scaling up clean heat through industrial electrification powered by renewable energy. Process heat is the single largest source of emissions in fashion supply chains, yet it is also one of the most solvable. This section is a litmus test of whether the industry is prepared to seize that opportunity.
Publishes timebound, measurable commitment to decarbonisation covering scopes 1 to 3
Publishes longterm (2040–2050) science-based targets aligned with the 1.5°C pathway (SBTi)
Discloses strategy or efforts to electrify supply chain manufacturing processes
Publishes measurable progress towards decarbonisation
Discloses a renewable energy target for the supply chain
Discloses a time-bound and measurable target to phase out combustion of coal on-site at finished garment factories
Discloses a time-bound and measurable target to phase out coal on-site at material processing/ manufacturing facilities
Discloses whether the coal phase-out target specifies the percentage of total production volume it applies to
Discloses progress against this renewable energy target
Discloses whether the coal phase-out target includes purchased steam
Discloses a renewable electricity target for the supply chain
Discloses
Discloses progress against the coal phase-out target in the supply chain
6
While more brands disclose Science-Based Targets, less than a quarter disclose how they will achieve these in the long-term, in line with a 1.5°C pathway
The good news is that the number of fashion brands with SBTi-verified emissions reduction targets covering Scopes 1–3 in the near term (e.g. by 2030) continues to grow, with 100 brands disclosing this in 2024 to 110 in 2025, up five percentage points from 50% to 55% of brands (See Box on pg. 47 for an explainer on why SBTi targets are important).
Many brands set short-term targets, but far fewer show how these build into medium and long-term commitments
However, only 24% of brands publish long-term sciencebased targets aligned with a 1.5°C pathway (2040–2050), signalling a gap between near-term ambition and the deep, sustained action needed to stay within planetary limits. Many brands set short-term targets, but far fewer show how these build into medium and long-term commitments — or cover all three. Despite the supply chain accounting for the majority of emissions, the methods to assess Scope 3 alignment are still evolving . There are no sector-specific, science-based benchmarks that reliably map emissions trajectories for complex value chains like fashion. These gaps underscore the importance of brands pursuing absolute emissions reductions, improving supplier data, and advancing sector-specific methodological frameworks. This is why it is critical for brands to disclose a comprehensive strategy with absolute emissions reduction targets across all three scopes, mapped to short-, medium-, and longterm horizons. 6
The need for emissions reductions by 2030 and Net-Zero by 2050 place enormous pressure on the supply chain. It is crucial to acknowledge that Big Fashion’s climate targets are often made without consultation with their suppliers, who are expected to achieve brand targets and even set their own. Our research this year finds that only 20% of brands consult with suppliers on their climate targets ( More on this in the Just Transition & Advocacy Section).
Transformers Foundation is an organisation representing a unified voice for the denim supply chain. In research published in 2023 , they highlighted supplier sentiments on fashion’s climate strategies. Suppliers explained that they expected to not only do most of the work to decarbonise but also fund these efforts, which is often impractical and inequitable. The burden of decarbonisation is disproportionately placed on suppliers in the Global Majority, despite historically and currently contributing the least to the climate crisis . The current top-down approach to sustainability, where brands dictate terms to suppliers, is deemed not only unfair, but ineffective. Transformers Foundation is calling for a collective approach where responsibility and resources are shared across the entire value chain. Importantly, in their view, Science-Based Targets often ignore the feasibility and context of different suppliers, particularly those in the Global Majority. Not all supply chain actors have the same capacity or resources to meet the same stringent targets, making the current approach inequitable. When putting pressure on brands to achieve climate targets, it is essential to acknowledge that meeting such goals must be done fairly and feasibly across the supply chain.
Fewer than a third (29%) provide evidence that they have actually reduced their greenhouse gas (GHG) emissions from the baseline
In our review, we awarded brands points where they have demonstrated a reduction in overall emissions from the base year of the target – irrespective of whether or not they had an absolute or intensity-based emissions reduction target. The findings show that just 29% of brands met this criteria. This means that less than a third of major fashion brands have publicly demonstrated they have actually reduced their emissions – even among those with verified climate targets. Importantly, progress data must include Scopes 1, 2 and 3. Without this, the full picture is incomplete, and the reality is that most major fashion brands are still not providing publicly available evidence that their total carbon footprints are actually shrinking.
We only accept targets that cover scopes 1, 2 and 3 (own operations and supply chain) and are verified by the Science Based Targets Initiative (SBTi). As the world’s most influential validator of corporate targets, SBTi plays a critical role in corporate climate commitments. We use the SBTI verification in this report to ensure standardisation of targets of all the brands reviewed and ensure accurate comparison between them. Without a standard framework for setting and communicating climate goals, corporate reporting would become disorganised and confusing, making accountability more challenging to achieve (than it already is!). The SBTi is currently consulting on an updated Corporate Net-Zero Standard (V2) , which would clarify the limited role of Environmental Attribute Certificates (EACs) – such as renewable energy certificates and carbon credits – in meeting targets. Under the proposal, high-quality carbon removals could be used for residual emissions only after deep, direct reductions across the value chain. At the time of writing, offsets remain prohibited for meeting SBTi-validated targets, and the priority continues to be cutting emissions at source.
The industry’s failure to show absolute emissions reductions is tied to the lack of sector-specific transition priorities, as highlighted by the NewClimate Institute . Too often, emissions-reduction targets stop short of driving the business model shifts needed for the critical transitions that global net-zero goals depend on.
Decarbonisation requires a comprehensive plan that covers both power and heat.
One reason, as outlined above, is that the current “rules of the game” – reliance on carbon credits, standalone renewable energy certificates, or offsetting – mask rather than prove, genuine corporate climate action. Overreliance on these accounting tools has not, and will not, deliver real-world emissions cuts. Absolute emissions targets, while important, are not enough. Time-bound, measurable plans to phase out fossil fuels (like coal), electrify production, and scale renewable electricity are the real markers of whether brands are on a credible pathway. Because transparency is so crucial, we ask:
• Are brands setting time-bound and measurable targets for renewable energy and renewable electricity in their supply chains?
• Do they disclose strategy or efforts to electrify supply chain manufacturing processes?
• Do they disclose a time-bound and measurable target to phase out combustion of coal on-site for finished garment factories and material processing facilities, and whether these targets specify the share of production covered and include purchased steam?
• Do they disclose progress against these targets?
The answers to these questions reveal how seriously the industry is taking the transition from ambition to real, measurable climate action and should be used as a lens to assess the comprehensiveness of a brand’s approach to both decarbonisation and electrification.
Brands who disclose targets without strategies to electrify and phase out fossil-fuelled heat risk locking in biomass or other stopgap solutions. Electricity may be renewable, but heating, cooling, and steam can still run on coal or gas. Decarbonisation requires a comprehensive plan that covers both power and heat.
Focusing only on renewable electricity leaves out most of a company’s energy footprint and most of its emissions. Both targets are needed to show credibility and transparency, drive market demand, and align with long-term climate goals. This dual focus supports robust corporate sustainability strategies and demonstrates a genuine commitment to addressing the climate crisis across all aspects of energy use.
Renewable electricity, generated from natural, carbon-free resources such as wind and solar, is a high-quality, sustainable alternative to fossil fuels like coal and fossil gas. Projects can be off-site, feeding into the grid, or on-site, such as rooftop solar installations, which are cost-effective and established in many regions. The cost of solar energy has dropped significantly, with prices decreasing by over 80% from 2010 to 2020 , making it cheaper than conventional fossil fuels in many cases .
With just 10% of brands disclosing a supply chain renewable electricity target and less (6%) a renewable energy target, the fashion industry is failing to set targets where emissions cuts matter most
Last year, 10% and 6% disclosed this, respectively –signalling that there has been no movement. This is a glaring gap in credibility where the greatest opportunities for emissions reductions lie – leaving fashion unprepared for the transformative action global climate goals demand.
Across all industries, we must reach 100% renewable and 100% electric by 2040.
The International Energy Agency is clear: across all industries, we must reach 100% renewable and 100% electric by 2040. Of the brands who disclose supply chain renewable energy and electricity targets, as the box below shows, not all targets are equally ambitious or aligned with the IEA benchmark. We recognise the leadership of those who have set these targets, as they are doing more than the majority of the industry. With such limited disclosure from billion-dollar fashion brands – those with the greatest power and influence to drive change – the sector remains far off track from climate science and collective, global targets.
Renewable Energy
ASICSdoesnotexplicitlydisclosearenewable energytargetforthesupplychain.
By 2030, source 85% renewable electricity used in Tier 1 factories.
H&M
Inditex (Zara, Bershka, Pull & Bear, Massimo Dutti, Stradivarius)
Mango
H&M does not explicitly disclose a separate renewable energy target for its supply chain. However, they have received credit for the prioritisation and detail covered by their renewable electricity target. The target covers 100% of Tier 2 – which has the greatest thermal energy demand and the hardest to decarbonise. Fashion Revolution would welcome either a renewable energy target with clear parameters on biomass and biofuels, or a renewable electricity target explicitly embedded within a broader electrification strategy, with transparent boundaries on what energy uses are included or excluded.
Inditexdoesnotexplicitlydisclosearenewable energytargetforthesupplychain.
By 2030: 100% renewable electricity for our garment production supply chain – from spinning to finished product in tiers 1, 2 and 3
By 2030, Mango will source a minimum of 30% of its production with renewable energy.
Lululemondoesnotexplicitlydisclosearenewable energytargetforthesupplychain.
By 2030, 50% renewable electricity in manufacturing processes in our supply chain.
By 2040, 100% renewable electricity in manufacturing processes in our supply chain.
By 2030, Mango will source a minimum of 30% of its production with renewable electricity.
By 2025, 25% renewable electricity among core suppliers.
By 2030, 50% renewable electricity among core suppliers.
Oniverse Group (Calzedonia, Intimissimi, Tezenis)
By 2040, 40% of total energy from renewable sources.
By 2030, 100% of directly consumed energy must come from renewable sources.
By 2030, 40% renewable energy at core factories (upstream, global)
By 2040, support of the supply chain in decarbonisation programmes to reach a target of 100% renewable electricity.
By 2025, 100% renewable electricity in facilities owned by the group.
Pumadoesnotexplicitlydiscloseaseparate renewableelectricitytarget.
Fuel for Heat
Fossil fuels are burned to create heat or power. In the fashion industry, this means boiling water for dyeing, washing, or bleaching fabrics, generating steam for fabric finishing processes like shrink control or wrinkle resistance, and running dryers or hot presses – all of which require heat. Around 70-80% of the consumption of the total energy in the processing of the fabric is thermal energy. In other words, fashion is energy-hungry because making clothes requires enormous amounts of heat. From boiling water for dyeing to producing steam for finishing, the bulk of the energy in fabric production goes not into running machines, but into generating heat.
Fuel as Fabric
Many synthetic fabrics like polyester, nylon, and acrylic are made directly from oil or gas. In this case, fossil fuels are the feedstock – the material that becomes the fibre itself.
Fuel for Electricity Generation
Electricity powers machines across the fashion supply chain — sewing machines, cutting machines, conveyor belts, lighting, fans, air compressors. But electricity is just the delivery medium. What matters is the source – clean energy like wind and solar, or dirty sources like coal and gas. When brands switch to electricity, the real question is: what’s powering the grid? In some cases, when not connected to the grid, factories burn fossil fuels on-site (like diesel generators). This is why electrification must go hand-in-hand with renewable energy targets.
Typical Temperature Range Process
Used for natural fibres like cotton
Dyeing with reactive dye
Scouring
Bleaching
Usedforsynthetic fibres like polyester–highertemperatures needed to open up the fibre structure so the dye sticks
Finishing agents like wrinkle resistance
Appliedto synthetic fabrics to fix fabric shape, structure and reduce shrinkage
Drying fabric or yarn
Dyeing with disperse dye
Curing
Heat setting
(under pressure)
Note:Seepg.56toseehowthese temperaturesstackuptootherindustries.
If heat is fashion’s hidden emissions hotspot, coal is its dirtiest fuel source. Coal-fired boilers remain common for generating the high temperatures needed for dyeing, drying, and finishing. Phasing out coal is therefore one of the most urgent steps brands can take to decarbonise heat and align with electrification and renewable energy goals. That’s why, alongside renewable energy targets, we also assessed whether brands are setting time-bound, measurable coal phase-out targets – and whether they are taking concrete steps to electrify these high-heat processes.
Last year, we found that just 15% of brands disclosed a target to phase out the combustion of thermal coal or other fossil fuels. This year, we refined our methodology to focus explicitly on coal. While this is a limitation of our research, we focus on coal because it accounts for up to 75% of thermal energy in the sector, and eliminating it by 2030 could cut emissions by 6% compared to a businessas-usual trajectory. Our research found that 21% of brands disclose targets to phase out coal combustion on-site at finished garment manufacturing facilities. This represents a notable increase of 6 percentage points from last year, showing some movement — yet with fewer than a quarter of brands disclosing such targets, the sector remains dangerously off pace on coal phase out.
A handful of brands (Calzedonia, Gildan, Hermés, Intimissimi, Tezenis) were able to demonstrate that they do not use coal in their supply chains – though this does not rule out reliance on other fossil fuels that also need to be phased out. What replaces coal is just as important; unsustainable biomass carries significant environmental impacts, and switching from coal boilers to so-called “transition fuels” like natural gas risks locking in long-term fossil fuel use. The transparency of replacement fuels is therefore essential for assessing whether coal phase-outs are genuinely advancing decarbonisation. All targets on coal phase-out are only credible when there is also accountability for its replacement.
To better understand the scope of brands’ coal phaseout strategies, we added several new indicators this year. Processing remains the biggest challenge, so we assessed whether brands’ coal phase-out targets included material processing/manufacturing facilities – only 18% disclosed this. We then looked at whether brands were transparent about the production volume their target applies to – just 9% disclosed this. Finally, and critically, we assessed whether brands include purchased steam in their targets, a key test of whether coal is truly being phased out. Hardly any do (2%), and the only brands awarded points here – Gildan and Oniverse Group (Calzedonia, Intimissimi, Tezenis) – are vertically integrated 7 and were able to clearly demonstrate they do not use coal as a fuel source to generate steam.
7 “Vertically integrated” means these brands own and directly manage multiple stages of production (from fabric mills to garment factories), giving them greater oversight and control over energy use compared to brands that outsource most of their supply chains.
Just 18% of Big Fashion brands have disclosed a coal phase-out target that covers material processing level (where the greatest challenge lies) and none publicly address purchased steam – leaving the industry behind on eliminating fossil fuels.
Many factories buy steam from nearby coal-fired combined heat and power plants or district heating systems – meaning they can claim to be “coal-free” on-site while still relying on coal indirectly. An example of why energy mix is important is because it gives visibility of how much comes from purchased steam and where it is generated. For example, H&M discloses that 77% of their supply chain energy consumption in China is from purchased steam (most of which is generated from burning coal). Including purchased steam in a coal phase-out target closes this major loophole.
Lack of transparency on purchased steam
means coal may still be embedded deep within fashion’s
production processes.
By covering purchased steam, brands ensure their commitments tackle all coal-derived heat in production – not just what is burned on their own premises – driving real emissions cuts and preventing coal use from being outsourced. Crucially, if multiple brands demand action on purchased steam, it could shift the equation entirely: collective pressure would create the leverage needed to push industrial zones to invest in cleaner infrastructure. While individual brands often claim they lack influence as “one buyer among dozens”, coordinated demand and financing are exactly what is required to unlock this transition.
The fact that hardly any brands include purchased steam in their supply chain targets raises a red flag: coal may still be embedded deep within fashion’s production processes. All major garment manufacturing hubs have fossil-fuel-heavy grids , making it even more important that coal phase-outs are paired with solutions that remove fossil fuels from the system entirely.
To truly eliminate coal from supply chains, brands must replace fossil-fuel-based heat with clean alternatives, and that means electrification powered by renewables. Big Fashion brands must pair ambitious targets with direct investment in technology upgrades that send a powerful market signal to grid planners. Rising demand for clean electricity will accelerate the shift to cleaner grids in garment-producing countries.
Our research found that just 6% of brands disclose any information on efforts to electrify supply chain manufacturing processes. This is highly concerning considering that the industry needs to transition to 100% electric and 100% renewable across all energy sources by 2040, according to the IEA . Replacing fossil-fuel-based heat with clean heat powered by renewables is one of fashion’s biggest opportunities for emissions reduction –yet most brands are not even talking about it.
Brand
Adidas
Discloses strategy or efforts to electrify supply chain manufacturing processes
Inditex (Bershka, Massimo Dutti, Pull&Bear, Stradivarius, Zara)
H&M
Hermès
Levi Strauss & Co
New Balance
“Process improvements and innovation: Develop and scale lower impact solutions in material processing, manufacturing, as well as product assembly that help us reduce GHG emissions (e.g. process electrification and low-temperature assembly).”
“To take this forward, we are working to drive supply chain transformation along three main lines: / energy efficiency / adoption of renewable electricity / phasing out fossil fuels, replacing them with electrified solutions or alternative fuels…as a result, we expect that at least 50% of the electricity used in the manufacturing processes in our supply chain will be from renewable sources by 2030, reaching 100% by 2040”
“We are working to eliminate fossil fuels like natural gas at our facilities. To this end, we are committed to electrification and the use of renewable electricity.”
“To meet the heat and steam energy demands in our textile supply chain, we prioritise electrification, supported by the procurement of renewable electricity, along with the use of ground or air-source heat pumps and on-site solar photovoltaic systems (PVs). Where electrification is not yet feasible, we prioritise producing thermal energy from agricultural residues as a transitional solution.”
“For example, the Vivoin tannery has launched projects aimed at completely eliminating its gas boilers by 2024 and thus reducing its use of fossil energy by 90% (lower temperature settings, elimination of the steam network in favour of electric heaters, heat pump installations and photovoltaic study).”
“Electrification and conversion to renewable energy across key tier 1 and 2 suppliers is the largest emissions reductions opportunity. To do this, suppliers will need to develop electrification and renewable energy procurement roadmaps, invest in retrofits, electrification, and where appropriate on-site renewable energy (i.e., solar).”
“Manufacturing textiles and other materials requires heat, and many fashion suppliers generate this heat by burning fossil fuels. As we push for a transition to renewables, electrifying textile production processes is an important step to decarbonise our supply chain. We continue to collaborate with GEI to deepen our understanding of the potential to electrify key parts of the textile supply chain. In 2023, we began two separate projects with GEI: Following our country-level analysis in 2022, we are assessing the feasibility of electrifying two textile mills by replacing fossil fuel-fired boilers with electric boilers or heat pumps. Transitioning to these alternative technologies is expected to reduce greenhouse gas emissions when paired with renewable electricity generation. The study is scheduled to conclude in 2024. Within the Outdoor Industry Association (OIA) Climate Action Corps, we are co-funding GEI to develop an industry tool to help textile mills quickly evaluate the potential of switching to electric boilers and heat pumps for their operations. This tool will hopefully accelerate electrification within the supply chain where it is shown to be most feasible.”
Some brands (e.g. Adidas and Inditex) mention electrification in broad terms, often as part of a longer list of decarbonisation measures, without providing detail on timelines, technologies, or scale.
Others (e.g. H&M, Hermès, New Balance) outline concrete steps, such as replacing gas boilers with electric boilers or heat pumps, installing on-site solar PV, or conducting feasibility studies – making their strategies more tangible and measurable.
Several brands (e.g. H&M, Levi Strauss, Inditex) explicitly link electrification to renewable electricity procurement, acknowledging that electrification without clean power risks shifting emissions rather than eliminating them. However, not all brands make this link clear, leaving questions about whether electrification efforts are paired with decarbonised grids or renewable sourcing.
Electrification
without clean power risks shifting emissions rather than eliminating them
Some brands focus on electrification within their own facilities (e.g. Hermès) while others address Tier 1 and Tier 2 suppliers (e.g. Levi’s) but few provide clarity on Tier 2, where the bulk of thermal energy is used.
A small number of brands (e.g. New Balance, H&M) reference pilot projects, feasibility studies, or ‘transitional’ measures like agricultural residue-based thermal energy (‘biomass’) where electrification is not yet viable. While this reflects an understanding of current technology and infrastructure constraints, it also raises critical questions about timelines – specifically, when these interim solutions will be phased out and replaced with clean electricity from truly renewable sources like wind and solar.
Brands like New Balance and Bestseller (Vero Moda and Jack & Jones) highlight collaborations with NGOs, industry alliances, or technical experts to assess electrification potential and develop tools for suppliers, signalling an awareness that system-level change requires shared resources and knowledge. However, collaboration must lead to tangible action. Pilot projects in brands’ own supply chains and beyond are critical to test real solutions, prove feasibility in different geographies and contexts, and de-risk investments for suppliers.
Overall, brands’ discourse on electrification within their sustainability reports is nascent. The industry is very much still in its ‘exploration’ and ‘feasibility’ phase. This reality sits at odds with the fact that the technology is widely commercially available.
The industry is still in its ‘exploration’ and ‘feasibility’ phase, which sits at odds with the fact that the technology is widely commercially available.
Electrification, more than any other solution, has the potential to reduce absolute emissions. The more brands that invest in electrification, the higher the demand for renewable energy – which ultimately helps accelerate the green transition in the global energy system. Public disclosure of these efforts is necessary and should be paired with renewable energy targets and renewable electricity targets for the supply chain. Crucially, brands must also build their own internal capacity and technical expertise on industrial electrification—ensuring decisionmakers understand the practicalities of heat pumps and electric boilers and other technologies—so that adoption can be accelerated. In parallel, as brands scale these technologies, they must embed electrification within a Just Transition framework—linking adoption with training, protections, and genuine worker participation. Without this, they risk exacerbating inequities and resistance in their supply chains; with it, they can cut emissions at scale while also securing lasting improvements in working conditions and shaping a more equitable clean energy future for the industry. See the Just Transition and Advocacy section for more on capacity building.
Heat pumps are the most effective solution, offering lower operating costs, higher efficiency, and the ability to cut emissions by making use of waste heat – excess heat from industrial processes that would otherwise be lost, but can be captured and reused.
• Use electricity to transfer heat from a source (air, water, waste heat) to where it is needed via a refrigeration cycle
• For every unit of electricity, deliver 2–5+ units of heat (200–500% efficiency), depending on temperature lift
• Can generate steam and hot water for industrial processes , with commercial units capable of up to 170 °C — meeting most textile process needs
• Can serve multiple temperature demands from a single system, and capture/process waste heat that would otherwise be lost
• High efficiency (often achieving 200% to 500% +)
• High cost and energy savings that help lower running costs (OpEX)
• Low-carbon (when paired with renewable electricity but still reduces emissions when paired with non-renewables)
• Widely commercialised technology
• No on-site air pollution
• Versatility (can provide both heating and cooling functions)
• Existing incentives in some regions
• The water is heated by using electric resistance elements (up to 5 MWe capacity) or electrode heating (from 3 MWe to 70 MWe) to produce steam
• Can also be used for thermal oil heating up to 400 °C for processes where a medium to high-temperature range is required
Challenges
• High upfront capital cost
• Technical expertise required
• Need for sustainable refrigerants phasing out HFCs/HCFCs in favour of natural refrigerants
• May be fewer manufacturers and suppliers in emerging markets
• Not a drop-in solution — integration may require significant process and infrastructure modifications
• High efficiency (up to 99%)
• Low-carbon (when paired with renewable electricity)
• No on-site air pollution ; quieter operation; faster ramp-up times
• Widely commercialised technology
• Lower capital, installation, and maintenance costs
• Easy to integrate — minimal disruption to existing internal processes
• Increase in energy costs due to electricity typically being more expensive than conventional fuels
• Possible near-term CO 2 increase if the grid is carbon-intensive
• Lack of supportive policies in some regions
Cost
High CAPEX
• Despite high electricity prices in many textileproducing countries, high efficiency can lower energy cost per unit of production and deliver acceptable payback periods
• Energy savings can offset operational costs , especially when combined with renewable electricity procurement
Supply & Infrastructure
• Growing commercial market with increasing industrial-scale availability
• Requires assessment of local grid capacity and potential infrastructure upgrades to handle increased electrical load
Lower CAPEX (around 40% less than an equivalent coal-fired boiler)
• High energy costs (electricity costs can represent up to 95% of lifetime boiler costs)
• Financial viability depends heavily on local electricity prices and renewable electricity (RE) availability
• Even with higher energy costs, the impact on final textile product prices may be small due to energy’s low share of total production costs
• Simple installation and maintenance
• Requires assessment of local grid capacity and potential infrastructure upgrades to handle increased electrical load
If fashion is serious about its climate targets, decarbonising heat must be a priority. While climate commitments are growing, clean heat is still missing from most plans. This year’s findings show how few brands are publicly addressing this emissions hotspot. Setting supply chain renewable energy and electricity targets and committing to phasing out coal-fired boilers are all critical steps – this does not necessarily mean a brand is actively pursuing clean heat by electrifying high heat processes. We need more brands to put clean heat at the centre of their climate plans and publicly report their efforts. Right now, the reality is clear: progress on clean heat remains alarmingly limited. The slow progress might suggest that clean heat is too hard to achieve – but that’s far from the truth.
Fashion is a light-manufacturing industry. While heat is essential in production, the temperatures required are significantly lower than in harder-to-abate sectors like steel or chemicals. For perspective, most fabric processing happens between 80–200°C, far below the 1,000°C+ needed in heavy industry. This makes the transition to clean heat not only technically possible, but achievable today. Fashion does not face the same technical barriers to electrification as other sectors (see below) and that creates a pivotal opportunity: the sector can lead the way.
Source: Sawe et al. 2024 analysis based on Rightor, et al. 2020 and Rissman 2022 THE
Academics, engineers, and energy experts agree: many processes can already be electrified using existing technologies (asthe Graph shows below). While there is currently no universal benchmark (e.g., “all processes under 150°C must be electrified by 2030”), research consistently shows that heat needs up to 150°C can already be electrified today using existing technologies and that process heat rarely exceeds 250°C, meaning it has the potential to move entirely away from fossil fuels.. Fashion is ripe for opportunities to adopt clean heat.
The Apparel Impact Institute highlights that technologies like electric boilers, industrial heat pumps, solar thermal, and thermal storage are already available and when paired with renewable electricity, can deliver low- or zero-carbon heat today.
In Europe, fashion is among the most electrification-ready sectors. Although sourcing countries across Asia face greater barriers – from grid reliability to renewable energy access – the opportunity remains clear: with the right investments and policies, clean heat can fuel fashion and set a new standard for industrial decarbonisation.
Source: Based on Madeddu et al. 2020 & Regulatory Assistance project (RAP)
When Big Fashion brands set a target for 100% renewable energy or renewable electricity for manufacturing, they send a powerful message: clean energy is a key factor in sourcing decisions. This influences not only suppliers, but also governments, industry peers, and grid planners in garment-producing countries, signalling that demand for clean power is rising. Pairing these targets with commitments to electrify supply chain processes ensures that electrification is built into grid planning from the outset. In other words: electrifying the factory floor helps clean the grid.
However, as electricity demand grows and fossil fuels are phased out, the power must be renewable and the grid must be ready. If factories and industrial sites switch from burning coal, oil, and gas to running on electricity, the world will need increasing amounts of electricity. Meeting this will require not just more renewables, but also major grid upgrades. To put it in perspective, in the next decade, we need to add as much new capacity to global energy grids as was built in the past 100 years .
Electrifying the factory floor helps clean the grid.
Big Fashion brands have a unique role to play in shaping this transition – not only through the electricity they purchase (see the Energy Procurement section), but also through their advocacy for greater access to renewable energy in manufacturing countries (see the Renewable Energy Advocacy sub-section). From engaging in policy debates on enabling measures like power purchase agreements (PPAs) to providing suppliers with financial support to adopt clean heat technologies, their choices can help unlock the infrastructure and market shifts needed to meet rising industrial demand.
Finally, the benefits of this transition go beyond cutting emissions. Shifting from fossil-fuel-based heat to clean heat powered by renewables has the potential to serve as both a mitigation and adaptation strategy. The benefits include reducing greenhouse gas emissions while potentially:
• Lowering indoor heat temperatures and air pollution levels from burning fuels
• Delivering health benefits, such as protecting workers from heat stress
• Reducing premature deaths from air pollution
More research and primary data is urgently needed to demonstrate and further corroborate these benefits. However, we cannot wait for ‘perfect data’ before acting, when the evidence is already clear on the dangers of burning fossil fuels and biomass. Workers are already on the frontlines of the climate crisis, and their health and safety are at stake [ 1 , 2 , 3 ]. We urge fashion brands to pilot clean heat solutions that are designed with benefits to workers in mind to help grow the evidence base.
A new American Lung Association study finds that swapping industrial boilers for electric heat pumps, especially in low-to mid-temperature processes, delivers clean, emissions-free heat and dramatically reduces air pollution. The study estimates that over the next 15 years, replacing industrial boilers across the United States with heat pumps could:
• Prevent 77,200 pollution-related deaths
• Avoid 33 million asthma attacks, 204,000 new asthma cases and the loss of 13 million school days and 3.4 million work days between 2030 and 2050.
• Yield $1.1 trillion in cumulative public health benefits, plus $351 billion in avoided climaterelated costs.
• Bonus: Approximately 9% greenhouse gas emissions in the US stem from industrial heat sources—so this switch also delivers significant climate mitigation
Discloses what type of energy is used in the company’s owned and operated facilities
Discloses the energy sources used for heating and steam in the supply chain 4%
Discloses what type of energy is used in the supply chain
Discloses details on how much electricity is used in the supply chain and where it comes from
Discloses a breakdown of energy consumption by country in the supply chain 4%
We cannot achieve a just, clean energy transition without disclosure of energy consumption data, particularly at supply chain levels.
Our research finds that while nearly half of brands (49%) disclose what type of energy powers their owned and operated facilities, far fewer (15%) do so for their supply chains —and only 4% break down supply chain energy use by country.
Transparency on energy mix by country in the supply chain would provide an added layer of visibility crucial for collective action. For example, knowing that energy use in Bangladesh might look like 60% fossil gas, 27% biomass, 10% imported oil, and 3% solar allows stakeholders to focus on how to support the shift to cleaner energy sources in Bangladesh—not move production elsewhere.
Just 4% of brands disclose data on what energy is used in the supply chain to create heat and steam, the most energyhungry process. This masks the industry’s reliance on fossil fuels.
This year, we added a new indicator asking brands to disclose the energy sources used for heating and steam in the supply chain. As indicated already in this research, the biggest challenge (and opportunity) for fashion is to power heat and steam from renewable sources. If brands do not disclose the energy sources used for heating and steam, it is impossible to know whether they are addressing one of their most carbon-intensive activities. Transparency here helps pinpoint where fossil-fuel-based heat is still used, track the transition to clean alternatives, and ensure that coal phase-out and electrification targets are actually reducing emissions where it matters most. Without this disclosure, coal phase-out and renewable energy targets cannot be meaningfully measured or achieved nor can brands be held accountable for achieving them.
Without clear, detailed data on where and how electricity is used in supply chains, commitments are impossible to verify and even harder to hold accountable. Yet, just 7% of brands disclose this information.
Knowing the total MWh (megawatt hours) consumed, how that breaks down by supplier, location, and process, and tracking this over time gives us a real picture of where emissions are coming from and whether reductions are actually happening.
If brands are not transparent about their electricity use, they are asking us to trust them on climate action without any proof.
Historical data also helps expose inconsistencies — such as claimed emissions cuts without a drop in energy use, or renewable energy claims (e.g. through unbundled Renewable Energy Credits) that do not match local grids. Without this level of transparency, brand claims risk being little more than accounting tricks. Without this level of disclosure, brand claims on renewable energy or emissions reductions remain unverifiable and risk misleading stakeholders. In short: if brands are not transparent about their electricity use, they are asking us to trust them on climate action without any proof.
If fashion is going to decarbonise at the pace required by the Paris Agreement , it needs a clear picture of its climate footprint – not just in its own stores and offices, but deep in the factories, mills, and farms that make its products. Without this visibility, not only is the industry unclear of the true breadth of the decarbonisation challenge ahead but we, as citizens and investors and regulators, are left without the information needed to hold it accountable.
Five years out from 2030, the discussion can no longer be just about emissions reduction through energy efficiency or renewable electricity procurement. We must be preparing supply chains for the shift to electrified clean heat; the single largest hurdle to removing fossil fuels from fashion’s manufacturing base. To better enable this transition, brands’ reported carbon footprints must reflect the real, location-specific emissions of the grids and fuels their suppliers rely on.
Publishes annual carbon footprint or GHG emissions in Scopes 1 & 2 (owned and operated facilities such as head offices, retail stores, distribution centres, warehouses, transport and mail orders)
Publishes annual value chain / Scope 3 carbon footprint (detailed GHG emissions from supply chain activities such as product manufacturing, material processing, textile production, raw material production, with estimations for downstream impacts)
Discloses a breakdown of Scope 3 emissions by country, volume, and emission type
The GHG Protocol is the global rulebook for how companies and governments measure and report their climate pollution. It provides a comprehensive global standardised framework to measure and manage greenhouse gas (GHG) emissions from private and public sector operations, value chains and mitigation activities. It requires companies to report their emissions across three main categories:
• Scope 1 : Direct emissions from on-site fuel use
• Scope 2: Indirect emissions from purchased energy such as electricity, steam, heat, or cooling
• Scope 3: All other indirect emissions across the value chain
Scopes 1 & 2
Emissions in scope 1 and 2 (under direct brand control) only account for approximately 3% – 5% of an organisation’s total GHG emissions and in some cases, it could be as little as 0.3%, as is the case for lululemon; less than 1% for Versace; and 2.0% for Aritzia. According to our data, nearly three-quarters of the world’s biggest fashion brands (72%) disclose their Scope 1 and 2 emissions.
Scope 3
Scope 3 usually represents a brand’s most significant greenhouse gas impact , highlighting the most critical area of need in the fashion industry. On average, 96% of emissions stem from scope 3 across fashion brands with approved science based-targets (SBTs). Within scope 3 emissions, more than 80% are upstream – all the products and services that a company buys (aka their supply chain), with the remaining 22% from downstream emissions, emissions associated with the use, disposal, and end-of-life treatment of the company’s products and services.
The data shows that 62% of brands disclose their scope 3 carbon footprint. This is a slight increase in comparison to last year’s 60% of brands. Scope 3 emissions reduction is where the greatest needs lie and yet, less than five years out from the global 2030 Paris target, 76 of the world’s biggest billion-dollar brands still do not disclose this information . There is a chance that they are tracking it and choosing not to disclose it or worse yet, they are not tracking it at all. There is no excuse to not be disclosing this information. It is baseline transparency. The data we DO have is merely the tip of the iceberg.
This year, we tracked brands’ disclosure on their Scope 1, 2 and 3 emissions. Before we dig into the analysis, it is important to understand the difference between locationbased and market-based emissions for Scope 2 accounting and reporting under the Greenhouse Gas Protocol.
For Scope 2 emissions, the GHG Protocol requires companies to report two figures:
• Location-based: the actual pollution from the electricity used, based on how clean or dirty the local grid is.
• Market-based: the emissions a company reports on paper, based on contracts or certificates (like PPAs, RECs, or green tariffs) that claim renewable energy use.
Market-based reporting, introduced only in 2015 , marked a significant shift from the previous location-only approach. Having both figures is essential for transparency: it shows stakeholders the real-world emissions from a company’s energy use and the claims it makes through purchased renewable energy instruments.
By contrast, Scope 1 and Scope 3 reporting is based solely on actual or estimated emissions – with no marketbased adjustment – to reflect the true climate impact of a company’s operations and value chain.
Scope 3 emissions aren not labelled as location-based or market-based because they come from things a company does not directly control, like the factories that make their products or the farms that grow their materials. These emissions are harder to measure and cannot easily be tracked using those same methods.
In our analysis, we reviewed brands’ disclosed emissions for Scope 1, Scope 2 (both market-based and locationbased, where available), and Scope 3.
For brands that clearly disclosed Scope 1 and Scope 2 using both accounting methods, we combined Scope 1 with each Scope 2 figure to provide a high-level estimate of their total operational emissions.
We acknowledge that:
• Emissions may be reported in different units , timeframes, or geographic scopes (e.g. global vs. regional),
• Some brands may omit or underreport parts of their operations (because the GHG Protocol allows them to – under the current rules, brands can decide what to include , and what to leave out of their emissions reporting. So, while the GHG Protocol sets the framework, brands draw the boundaries) –resulting in a lack of standardised boundaries.
• The data may not always be directly comparable across brands.
As such, this is not a precisefootprint analysis , but a rough comparison to better understand how brands are accounting and disclosing their operational emissions.
Scope 1 & 2:
Scope 1 & 2:
Our research finds that just 62% of brands included in the scope of this research disclosed their Scope 3 emissions, which amounted to:
1,104,048,445 TONNES OF CO 2 E
9
In our review, we found that:
• Market-based emissions are lower than locationbased for most brands. This typically reflects use of renewable energy certificates (RECs), power purchase agreements (PPAs), or other clean energy procurement. This does not automatically mean a brand is driving real-world decarbonisation – it could simply be a reflection of accounting choices and lowering emissions on paper.
• Market-based emissions are higher than locationbased for some brands. This suggests that the brand may be sourcing energy from contracts that are actually more polluting than the local grid average – or not using any renewable procurement strategy at all.
• Missing or incomplete data. Some brands report only one figure. In fact, 17 brands who disclose market-based Scope 2 emissions did not report, or it was not clear, what their location-based emissions were. While this data may exist in CDP filings, SBTi submissions, or regulatory reports, withholding one side from public view creates a transparency gap, leaving room for selective reporting and undermining accountability. Importantly, the GHG Protocol is an accounting standard, not a law, which is why it is important for legislation to fill the gaps – like the Corporate Sustainability Reporting Directive (CSRD) which requires reporting companies to disclose both market-based and location-based emissions.
Without full and consistent reporting of Scope 2 emissions,
So, although 144 out of 200 brands disclose their footprint for Scope 1 and 2 emissions, far fewer – just 95 brands –disclose both Scope 2 market-based and location-based emissions. The bottom line: Without full and consistent reporting of Scope 2 emissions, brands leave the door open for greenwashing but also expose themselves to compliance risks under new rules like the CSRD.
This is not the full picture. It is the floor, not the ceiling. Brands that do not disclose anything are still driving emissions – including all the brands not included in the scope of this research.
1.1 billion tonnes of CO 2e is equivalent to:
• Burning roughly 2.56 billion barrels of oil 10
• Burning about 3.85 million railcars full of coal
• ~2% of total global emissions 11
… And that’s just for the 124 brands out of 200 in the scope of this research who disclose their emissions.
To put that into perspective: the 124 billion-dollar fashion brands that disclosed their Scope 3 emissions emit more than Vietnam and Bangladesh combined, more than twice Vietnam’s (524 MtCO 2e) and nearly four times Bangladesh’s (281 MtCO 2e) emissions in 2023 .
10
11
Just 3% of brands disclose supply chain emissions by country — a crucial gap, especially for brands that also withhold supplier lists. Without this transparency, the industry’s biggest challenges remain hidden.
Last year, 5% of brands disclosed their Scope 3 emissions by country, volume, and emission type. This level of disclosure, more granular than most reporting frameworks require, enables a clearer understanding of where emissions are concentrated and where action is most urgently needed. Brands disclosing last year included American Eagle, Balenciaga, Bottega Veneta, Champion, Gucci, Hanes, JD Sports, lululemon, OVS, and SAINT LAURENT.
This year, however, disclosure has dropped to just 3% (5 brands): American Eagle, Gildan, Hanes, OVS, and Puma. Among them, OVS goes further by publishing the share of emissions in each country. For example, 58% of its scope 3 footprint comes from Bangladesh.
While this is not common practice, such disclosure sets an important benchmark. It allows for more targeted emissions reductions, highlights where responsibility lies, and provides a stronger basis for collaborative climate action. Crucially, when paired with supplier lists, emissions hotspot data helps test the credibility of brands’ climate transition plans. The purpose of this visibility is not to shift sourcing to ‘cleaner’ countries, but to enable brands and their stakeholders to advocate for and support the transition to cleaner grids in the regions where they already produce.
The findings of the Decarbonisation section are underscored by a stark reality: 76 out of 200 brands score zero in this section. Looking specifically at the United States, out of the 74 US-headquartered brands assessed, nearly a third (32%) score zero on Decarbonisation — and over a quarter (28%) score zero across the board. For the world’s largest fashion market , this sends a clear message: climate action is not high enough on the agenda. It exposes a glaring leadership gap at a time when the stakes could not be higher. If billion-dollar fashion brands will not be accountable by choice, they must be accountable by law.
Aeropostale
AJIO
Anthropologie
BCBGMAXAZRIA
Beanpole
Belle
Billabong
Bosideng
Buckle
Champion
Chico’s
Columbia Sportswear
Deichmann
Dick’s Sporting Goods
Dillards
DSW
Eddie Bauer
Express
Fashion Nova
Forever21
Free People
Heilan Home
Hudson’s Bay
Jack Wolfskin
Lands’ End
LC Waikiki
LL Bean
Matalan
Max
Max Mara
New Yorker
Nine West
Quiksilver
Reebok
Reliance Trends
REVOLVE
Roxy
Saks Fifth Avenue
Semir
Smart Bazaar
Splash
Ted Baker
TOPVALU COLLECTION
Tory Burch
Urban Outfitters
“ The state of the industry is clear: the system is not working. Some companies have set targets, but few have credible plans for follow-through. This is not a criticism of sustainability teams, who often work tirelessly with limited resources and internal influence. Nor is it necessarily a knock on executives, who operate in a system of relentless pressure to deliver quarterly earnings. The truth is that after the low-hanging fruit, sustainability requires investments with less-than-ideal payback periods—and sometimes, doing the right thing simply costs more. That’s why we need corporate leadership to name the systemic challenge and advocate for common-sense rules.
Dupont did this with CFCs and the ozone layer—calling for enforceable laws. Today, the ozone is healing not because of voluntary pledges, but because of binding rules with teeth. Fashion needs the same. Only enforceable standards can level the playing field so doing the right thing is not a competitive disadvantage.
The Fashion Act bills being advanced in California and New York create these common-sense rules. Corporate leaders should be rallying behind them. The climate crisis is not going away because it is inconvenient. Leadership is doing the hard things—the things that build your legacy.”
Maxine Bedat Director, New Standard Institute
What are fashion brands revealing about how they buy and report renewable energy use, and how effective and impactful are these approaches?
In this section, we try to understand major fashion brands’ progress on adopting renewable energy through their commitment to the RE100 initiative – a pledge companies take to procure 100% renewable energy in their own operations.
Discloses commitment to RE100
We also assess how transparent brands are about their energy procurement strategies – both for their own facilities and across their supply chains – and whether they are actively supporting the transition to renewable electricity. This includes disclosure of the procurement methods used, which is essential to judge the robustness and credibility of their approach.
Alongside this, we are evaluating transparency levels on the scope and scale of renewable energy use and production in the supply chain by looking at the percentage of electricity consumption that is matched to renewable energy hourly – also known as 24/7 hourly matching, a crucial measure of whether or not fashion brands’ efforts are aligned with the energy transition .
11%
Discloses how the company sources energy for its own facilities (e.g. head office, retail stores, distribution centres, warehouses), including whether self-generated, via PPAs, energy suppliers, or renewable energy certificates (EACs/RECs)
Discloses how energy is sourced in the supply chain (e.g. product manufacturing factories, material processing, textile production, raw material production), including whether self-generated, via PPAs, energy suppliers, or renewable energy certificates (EACs/RECs)
Discloses share/percentage of supply chain electricity consumption matched on an hourly basis (24/7 hourly matching)
Electricity powers many components of modern fashion production – from factory lighting to sewing machines to emerging clean heat systems replacing coal boilers. However, the climate impact of that electricity depends entirely on the grid mix in the country where it is consumed or the availability of onsite renewable electricity e.g. rooftop solar.
A grid is the interconnected network that delivers power from where it is generated – coal plants, gas turbines, wind farms and solar parks – through transmission lines to garment factories, other businesses and our homes. In many fashion production hubs, these grids are still dominated by fossil fuels. That means even if a brand electrifies its processes, the electricity may still come from coal or gas unless renewable capacity is added to the grid.
This is why energy procurement matters. How brands choose to source their electricity – and the extent to which they create new renewable supply in the places they operate and source from – determines whether their decarbonisation strategies have real impact or just shift emissions from one part of the system to another.
When brands invest in high-impact procurement methods — like on-site generation or local Power Purchase Agreements (PPAs) that directly bring new wind and solar projects online — they send a system signal: demand for clean energy that accelerates the shift away from fossil fuels.
Renewable Energy Certificates risk masking fossil fuel dependence
The opposite is also true. Lower-impact methods, like buying unbundled Renewable Energy Certificates (RECs), do not add renewable capacity where it is actually used. They risk masking fossil fuel dependence and slowing the pace of grid decarbonisation in the countries where fashion’s climate footprint is largest. Claiming “100% renewable electricity” based on RECs can give the false impression of clean power 24/7, like buying solar credits to cover coal use at night. Without a link between where and when renewables are generated and consumed, fossil fuels still fill the gaps.
Self-generation
Power Purchase Agreements (PPA)
Standalone and/or unbundled Energy Attribute Certificates (EACs)
Renewable Energy Certificates (RECs)
Producing renewable energy on-site rather than purchasing it from external suppliers. It can take the form of:
• Solar panels
• Wind turbines
• Other renewable technologies installed on company premises
Self-generation allows brands to directly control and utilise renewable energy, contributing to a reduction in their overall carbon footprint and helping to ensure a more sustainable energy supply chain.
A Power Purchase Agreement (PPA) is defined as a contract between a company and a renewable energy producer, where the company agrees to purchase electricity directly from the producer. This arrangement often involves the development of new renewable energy projects and contributes to the expansion of renewable capacity.
PPAs are typically considered higher-quality procurement instruments because they are more likely to result in the generation of additional renewable energy and are often tied to specific projects and locations, ensuring a direct link between energy production and consumption.
A ‘bundled’ REC (Renewable Energy Certificate) is sold together with the actual electricity produced from a renewable source. This means when you buy the electricity, you also get the certificate verifying that the electricity is renewable. One REC represents 1 MWh of renewable electricity.
Less effective still is an unbundled REC which is sold separately from the actual electricity. You can buy the certificate even if the electricity you are using comes from non-renewable sources. The certificate alone claims that a certain amount of renewable energy was generated somewhere, but it does not mean that the electricity you are consuming is directly from renewable sources
RECs do not send a demand signal to clean the grid where the electricity is actually consumed. This disconnect undermines local renewable development and delays the conditions needed to scale emerging solutions like electrified clean heat.
This report does not provide a detailed brand-by-brand analysis. As in last year’s report, detailed data was often scarce. Most brands’ supply chain procurement strategies lack transparency on the procurement type, location, volume, demand coverage, and certificate arrangements, all of which are essential to assess brands’ ambition levels . Some information was available via CDP (formerly Carbon Disclosure Project) reports, but overall transparency remained limited. Therefore, we awarded points where brands disclosed at least the type of procurement construct in use.
More Big Fashion brands than last year (20% up from 17%), are publicly committing to 100% renewable electricity in their own operations through the RE100 initiative.
Membership of RE100 remains the clearest signal of commitment to renewable electricity in brands’ own operations (scopes 1 and 2). While the increase is small, it reflects growing demand for renewables and supports wider market shifts. While there are other initiatives similar to RE100, such as the Clean Energy Buyers Association (CEBA) , we prioritise RE100 due to its global reach.
Nearly two-thirds (60%) of brands disclose how they source energy for their own operations, but only 11% do so for their supply chains – where the majority of energy is consumed.
This blind spot makes it impossible to know if brands are adequately supporting suppliers with the energy transition, especially the shift to electrified, clean heat.
No contract or certificate can override the laws of physics – until we clean the grid, fossil fuels keep burning.
Transparency of renewable energy procurement strategies is crucial to understanding not just how brands are decarbonising their own operations, but whether they are enabling the clean energy supply their suppliers will need in the coming years.
While this report did not score brands on procurement methods, our review found many relying on unbundled renewable energy credits (RECs) to offset emissions at both their own operations and across their supply chains. These certificates may improve the numbers on paper, but they do little to change the fossil-heavy grids that garment factories depend on.
Herein lies the problem: it is a practice of accounting and not accountability. No contract or certificate can override the laws of physics – until we clean the grid, fossil fuels keep burning.
For the second year, we measured whether brands disclose the share of supply chain electricity consumption matched on an hourly basis — and again, none do. Unlike annual or monthly matching, 24/7 ensures electricity use is matched with renewable generation every hour, providing a true picture of emissions. Think of it like budgeting: staying under your monthly limit does little to help if you overspend most days. Hourly matching ensures you live within your means every hour.
Hourly matching can help stabilise grids, cut reliance on fossil fuel plants, and accelerate progress towards climate targets
Currently, Denmark is the only country with over 50% of energy from solar and wind, but global coalitions — including Climate Group 24/7 Carbon-Free Coalition and the UN’s 24/7 Carbon-Free Energy Compact — are pushing this as the future standard. By enabling robust emissions tracking and signalling demand for clean electricity, hourly matching can help stabilise grids, cut reliance on fossil fuel plants, and accelerate progress towards climate targets – an urgent priority given that corporate electricity use accounts for half of global demand
This is also why the revision of the Greenhouse Gas Protocol matters. Stronger rules could make hourly, gridspecific matching the norm — closing loopholes that allow companies to report “clean” energy on paper while still relying on fossil power in practice. If fashion brands are serious about climate leadership, now is the time to back these reforms and adopt 24/7 hourly matching themselves.
A Big Fashion brand might state that 20% of its “renewable” electricity comes from RECs, suggesting partial progress toward a 100% goal. In reality, the physical electricity could still be generated from coal or gas, which is not real progress.
The last decade of corporate sustainability has been defined by target setting, primarily through promises to reach net zero emissions by a certain year, probably at least a decade after the current CEO retires.
On one hand, this movement towards sweeping commitments was, as climate analyst Ketan Joshi points out, effective at building broad initial support for companies to take responsibility for their emissions, in alignment with the Paris Agreement. On the other hand, as the media applauded each newly approved ScienceBased Target, the implementation of solutions to actually reduce emissions in real life was nowhere to be seen.
In What Fuels Fashion? , for example, 55% of brands have disclosed a time-bound commitment to decarbonisation, but only 29% have made any measurable progress against their baseline year emissions.
Is it a win-win for business and the planet, or just an accounting trick that enables major emitters to evade accountability?
To address this chasm between ambition and action on ‘net zero’, the multi-billion-dollar carbon credit industry emerged to offer companies a way to appear carbon neutral on paper, while doing none of the work to clean up their fossil fuel-guzzling operations. Is it a win-win for business and the planet, or just an accounting trick that enables major emitters to evade accountability? Who cares, as long as carbon credits are accepted as a valid mechanism to offset emissions by the most widely used carbon accounting framework, the GHG Protocol. This same twisted paradigm is playing out in the realm of renewable energy. To complement their emissions reduction targets, an increasing number of companies are also promising to increase the consumption of renewables in their operations and supply chains. But despite this momentum of corporate clean energy procurement, real-world emissions and fossil fuel consumption are only increasing. How could this be?
RUTH MACGILP
Fashion Campaign Manager Action Speaks Louder
Renewable energy certificates (RECs), which in theory represent 1mwh of energy generated from renewable sources, operate in much the same way as carbon offsets. A company can burn 1mwh worth of coal in its factory, but as long as it purchases one REC from an old wind farm, perhaps in a completely different country to the factory, the emissions from burning that coal are completely cancelled out. In other words, buying that one REC does not mean that the company has directly used 1mwh of wind energy.
In the fashion industry, where only 13% of brands disclose how energy is being procured in the supply chain, RECs dominate most corporate claims of renewable electricity consumption. This concerning reality is enabled not only by the market— which proliferates artificially cheap certificates (as little as $0.30 USD per MWh), offering little incentive to invest in establishing real renewable energy infrastructure—but also by the carbon accounting rulebook the majority of brands follow. Although it may look better on paper for brands to report reduced emissions and increased consumption of clean electricity, it is unlikely to displace fossil fuels at the pace and scale required to truly transform the global energy system.
If the rules of the game are sufficiently strengthened, the next decade could finally move from target-setting to target-achieving
Fortunately, there is a timely opportunity to redirect this rulebook to incentivise real change in the corporate energy procurement landscape. Right now, the methodology behind the GHG Protocol is under review. Support is growing for a transition to granular reporting of real-time renewable electricity generation and consumption, as well as the rejection of carbon offsets as a primary means to achieve emissions reductions.
If the rules of the game are sufficiently strengthened, the next decade of corporate sustainability could finally move from target-setting to target-achieving, because stricter accounting rules necessitate real-life action to reduce emissions. Maybe, if we build integrity and accountability beyond the headline promises, the so-called ‘corporate climate retreat’ of 2025 would not be such bad news after all.
In this section, we measure what brands are disclosing on their efforts to finance the decarbonisation of their supply chains and to invest in climate adaptation measures that protect workers and production sites from climate-related hazards.
We begin by looking at whether brands identify climaterelated risks, such as floods, droughts, or heatwaves, that could have a substantive financial or strategic impact on their operations. This aligns with the CDP questionnaire and the recommendations of the Task Force on ClimateRelated Financial Disclosures (TCFD). Disclosure of these risks through a financial lens is important because brands that publicly recognise the cost implications are more likely to take meaningful action to mitigate them.
Decarbonising fashion’s supply chains requires more than one-off investments – it demands ongoing support.
Shifting from fossil fuels to renewable energy and replacing coal- and gas-fired boilers with clean, electric heat technologies, alongside energy efficiency upgrades and new low-impact processes such as waterless dyeing and other innovations, demands both capital expenditure (CapEx) and operational expenditure (OpEx) in support of supplier decarbonisation, which is why we updated our assessment this year to focus on both.
• CapEx (Capital Expenditure):
Upfront investments in renewable energy infrastructure, clean technologies, or energy-efficient manufacturing equipment, and clean heat technologies such as heat pumps and electric boilers, to reduce energy consumption and lower greenhouse gas emissions.
• OpEx (Operational Expenditure):
The ongoing costs of running those systems e.g. the costs associated with switching to renewable energy and electrification in supply chain facilities.
Looking at both upfront and ongoing costs reflects the reality that suppliers cannot be expected to shoulder the full cost of a transition that is being driven by brand climate targets. A genuine partnership approach means brands must share responsibility for financing the transition they are requiring of their suppliers, ensuring that decarbonisation and adaptation measures are both affordable and accessible across the supply chain.
Finally, we have tracked whether brands disclose their CapEX investments for climate adaptation measures that directly protect workers and safeguard production from the impacts of the climate crisis, such as installing cooling or ventilation systems to reduce heat stress and constructing flood defences for at-risk facilities. These investments are critical for delivering a Just Transition, ensuring that climate action addresses both environmental objectives and the rights and wellbeing of workers – where Big Fashion brands are committed to staying and fixing rather than simply shifting business elsewhere.
Ultimately, nowhere on earth will be untouched by the climate crisis so our focus must be on future resilience.
What matters most is transparency on the actual amounts invested — how much brands are funding, and what it covers. We want to see, in writing, whether fashion brands are truly putting their money where their emissions are. That’s why we prioritise disclosure of brands’ own financial commitments — not simply their disclosure on the efforts of multi-stakeholder groups that they are members of. Those initiatives matter, and we do not diminish their importance, but ultimately Big Fashion brands must also have their own skin in the game.
This focus on financing reflects the broader aim of the report: to move beyond headline climate commitments and interrogate whether brands are investing in the real systems change required. Transparent disclosure of CapEx and OpEx determines whether brands are backing their climate promises with meaningful financial commitments that drive both decarbonisation and justice across fashion’s global supply chains.
Provide details of climate-related risks identified with the potential to have a substantive financial or strategic impact on your business
Discloses the brand’s total annual investment and the type of financial support provided to suppliers for capital expenditure (CapEx) aimed at meeting supply chain decarbonisation targets
Discloses how the brand is supporting their suppliers with operational expenses (OpEx) required to meet brand supply chain decarbonisation targets, particularly in transitioning to renewable energy and electrification
Discloses brand investment in capital expenditures (CapEx) for climate adaptation measures, such as installing air conditioning or other cooling systems to mitigate heat stress in supply chain facilities and flood defenses
Fashion supply chains are already being disrupted by the climate crisis , from floods and droughts to escalating heatwaves. For major brands and retailers, understanding these environmental risks and their financial implications is essential to future-proofing business. Yet, a little more than half (57%) of brands provide details of their climaterelated risks – such as floods, droughts and heatwaves. Beyond the moral imperative to do so, the fashion industry must gain an in-depth understanding of climate-related risks which in turn would support their strategy to reduce their greenhouse gas emissions (mitigation) and build resilient supply chains able to navigate the impacts of the climate crisis such as heat and floods (adaptation). Without this data, not only is business resilience undermined but also investor confidence.
Manufacturing is capital-intensive, and decarbonising both industry and production can be costly in the short term. Under the Polluter Pays Principle, the costs of environmental damage should be borne primarily by those most responsible — in this case, the brands driving production — rather than shifting the bulk of costs onto suppliers.
Achieving net-zero by 2050 will require an estimated USD $1 trillion in financing across the fashion system — involving brands, suppliers, financiers, governments and philanthropy. Within this, brands have a particular responsibility to lead as financing partners, not just purchasers.
The costs of environmental damage should be borne primarily by those most responsible
Many suppliers, particularly in Global Majority garmentproducing countries, cannot access affordable or adequate financing , making brand support essential. Without significant brand-led investment, the industry will struggle to meet its targets.
Suppliers’ contributions should therefore be limited to proportionate, financially viable measures — particularly interventions with clear payback periods — but small and medium-sized suppliers in particular cannot reasonably be expected to shoulder the primary burden of transition finance. As the Apparel Impact Institute (Aii) highlights , suppliers need capital and support to act, but are often credit-constrained; without brand-led financing and collaborative partnerships, their decarbonisation potential remains stalled.
For many suppliers, ‘transition’ means absorbing high up-front costs and taking on new debts, even where operating costs fall over time. To illustrate the scale, some manufacturers, in the Fashion Charter’s Manufacturers Peer Action Group stated that projects and equipment required upwards of €1 million in investment for structural modifications like installing rooftop solar panels, among other upgrades.. According to a World Wildlife Fund’s case study of a specific factory in Vietnam, switching to an electric boiler would require an investment of $88,000 and a running cost of $99,000 whereas a heat pump would cost an estimated $440,000, with a running cost of $59,000 per year for renewable electricity (excluding additional installation costs and electricity upgrade investments). Finally, using AII’s Clean by Design data for the average cost of energy efficiency improvements by region and tier (from $20,350 per facility up to $1,010,000), the global weighted average energy efficiency investment was calculated to be $178,924 per facility.
The central responsibility rests with brands, whose purchasing practices and financial power shape the system
For suppliers already working within fragile financial models, these costs are prohibitive without brand support — particularly when buyers do not provide stable, longterm contracts. Many operate on very slim margins, if any, and face significant climate risks alongside wider economic uncertainty, including tariffs . This is compounded by unstable purchasing practices — such as compressed lead times, frequent order changes, or downward pressure on prices — which restrict cash flow, limit access to credit, and undermine their capacity to plan, absorb risk, and invest in decarbonisation.
External co-financing from multilateral development banks, governments, or philanthropy can play an important complementary role. But the central responsibility rests with brands, whose purchasing practices and financial power shape the system.
• In 2021, a solar developer financed and installed 8 MW of rooftop solar across two textile facilities in Vietnam. The project cost totalled $5.6 million (~$700 per kW) and was covered by the developer through private equity financing. The facilities signed 15-year PPAs at a discounted rate compared to the local utility, generating ~US$135,000 in annual savings for the manufacturers.
• A wool scouring facility in New Zealand invested $9.5 million to replace a coal-fired boiler with an electric one , with costs shared between Woolworks and the government’s EECA Decarbonising Industry Fund.
The Fashion for Good “Future Forward Factories” project also offers a practical pathway for decarbonising textile production. By piloting technologies and financing approaches in real facilities, it demonstrates how suppliers can be supported to achieve deep emissions cuts in practice.
According to Aii, transitioning to renewable electricity could abate 27% of supply chain emissions — underlining its central role in fashion’s climate transition. However, the challenge differs by tier: while Tier 3 relies mainly on electricity, making renewables a more direct substitute, Tier 2 remains 75–90% dependent on thermal energy from coal. Here, rooftop solar or wind cannot replace fossil fuels alone; brands must invest in electrified clean heat solutions, such as heat pumps and electric boilers, alongside broader grid decarbonisation efforts.
Many CapEx investments in renewable energy and efficiency upgrades — such as rooftop solar, efficient boilers, and wastewater heat recovery systems — can pay for themselves within 3–7 years through lower energy bills and operational savings, after which they continue to generate cost reductions for the lifetime of the equipment. However, other technologies, such as electric boilers, can be more expensive to operate than coal due to the relatively high cost of electricity in many regions, meaning they require brand financing or policy incentives to become viable.
Other analyses note that these technologies become most financially viable when the spark gap closes — in other words, when electricity prices fall below gas or coal — highlighting the need for brand financing and supportive policies to accelerate adoption. Government incentives, such as feed-in tariffs, can further de-risk projects and make viable those that might otherwise be uneconomic.
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Despite this reality, only 6% of brands disclose annual CapEx investment in renewable energy infrastructure or energy-efficient solutions, and just 2% disclose financial support for the increased operational expenses suppliers face in making this transition. Where disclosed, investments range from USD $84,000 (GAP Inc.) to USD $159.8 million (H&M), including initiatives to phase out fossil fuels, improve efficiency, and replace conventional materials. Although initiatives like the Aii Fashion Climate Fund provide grants and subsidies for initial sustainability initiatives, including technical assistance and carbon roadmapping, we need to see greater transparency from brands on how they are funding and supporting this transition.
Financing alone will not solve everything. Many facilities in garment-producing countries still rely heavily on coal and diesel, and electrification often creates a ‘double cost bind’ – meaning high CapEX for new equipment and higher OpEX if grid electricity is more expensive than fossil fuels. Parallel investment is needed to help decarbonise national grids. However, we do not need to wait for perfect grids to take action.
Global Efficiency Intelligence research finds that electrification of a typical textile facility in India can reduce energy use and emissions, even with low levels of renewable energy procurement. By 2050, if heat pumps are adopted across India’s textile industry, emissions could nearly be eliminated, even with 50% electricity still sourced from the grid. Under a scenario with more ambitious renewable energy procurement, emissions would drop to zero.’ As of July 2025, half of India’s installed power capacity comes from nonfossil fuel sources – a milestone achieved five years earlier than its 2030 target. This progress in one of the world’s major garment hubs shows that electrification is possible.
On the adaptation side, extreme heat is an escalating risk . This not only impacts workers’ health, but also their productivity. Research from the Global Labour Studies Institute at Cornell University suggests that by 2030, Dhaka’s Ready Made Garment (RMG) workers could face 65 lost working days per year due to heat, with combined heat and flood impacts costing the Bangladeshi industry USD $27 billion and 255,000 jobs. Yet only one brand group, Oniverse, who owns Calzedonia, Intimissimi, Tezenis, disclosed an adaptation investment — €1.2 million for cooling systems and water recovery in Tunisia at a facility called Zriba, where wet processes are in place. Major brands and retailers must take a worker-centered approach to ensure initiatives that improve energy efficiency and climate adaptation while safeguarding the health and wellbeing of their workers, as outlined in the Just Transition and Advocacy section.
The United Nations Framework Convention on Climate Change (UNFCCC) identifies three major obstacles to decarbonisation:
• Contextual differences — policy, infrastructure, and financing gaps in producing countries.
• High costs of industrial transition — both CapEx and OpEx.
• Systemic risks — current costing models fail to account for needed decarbonisation investment.
These can be overcome through:
• Strategic commercial partnerships — long-term brand-supplier relationships that enable co-investment in decarbonisation.
• Knowledge-sharing forums — coordinated by multi-stakeholder initiatives like the Fashion Charter, tailored to local contexts.
• Policy advocacy — ensuring governments adopt incentives that support renewable energy and industrial electrification.
This section assesses how transparent major fashion brands are about supporting a clean, fair, and just energy transition in their supply chains. Our assessment of brands’ Just Transition policies are guided by the principles set out by Climate Action 100+ , the World Benchmarking Alliance and the We Mean Business Coalition . We also utilised the International Labour Organisation’s Just Transition Guidelines , as well as alignment with the UN Guiding Principles on Business and Human Rights (UNGPs).
First, we examined whether brands publicly commit to a Just Transition and disclose how they work with suppliers to achieve it. This includes disclosure on how brands consult and co-create climate targets with suppliers, rather than imposing top-down decisions, and how they support suppliers to adapt to climate risks in ways that are sensitive to local and regional contexts. Updated guidance for 2025 recognises brands that disclose support for suppliers in setting their own context-specific climate targets, including verified ones such as SBTi-approved goals.
Second, we looked at how brands engage workers and local communities who are affected by their climate strategies. We assessed disclosure on how brands co - create solutions with those most impacted, including how they retain, re - skill, and up - skill workers whose jobs are at risk due to the climate crisis or changes driven by the brand’s decarbonisation strategy. We also looked at whether brands disclose how they compensate workers affected by climate hazards or transition impacts.
In 2025, we expanded our assessment to include how brands address heat stress in their supply chains – a significant and rising occupational health risk for garment workers in hot and humid production regions. We focused on public disclosure of primary, real -time heat and humidity data from supplier facilities. This is a critical transparency gap in the sector. Making this data public allows manufacturers, unions, and brands to establish baselines, understand when worker safety thresholds are exceeded (e.g., Wet Bulb Globe Temperatures above 30.5°C), and inform adaptive measures such as ventilation upgrades, cooling systems, and flood defences.
We also evaluated the extent to which brands publicly disclose how they enable fundamental labour rights, in particular, freedom of association and collective bargaining. These are enabling rights, forming the foundation for meaningful social dialogue that allows workers to organise, negotiate, and influence decisions affecting their working conditions and livelihoods. We looked for evidence that independent, democratically elected trade unions are active in the brand’s supply chain and that collective bargaining agreements are in place and cover workers meaningfully. These rights are central to a credible Just Transition because, without them, workers and communities cannot effectively participate in shaping climate adaptation or mitigation strategies.
Finally, we assessed what brands publicly disclose about their renewable energy advocacy and its outcomes in their supply chains. Many garment production regions face structural barriers to accessing renewable energy, and major fashion brands can play a pivotal role in driving change through their purchasing power and influence. We also examined whether brands’ renewable energy strategies are rights - respecting, including avoiding solar panels and components linked to state - imposed forced labour (SIFL), and whether these expectations are communicated to suppliers.
Publicly commits to a Just Transition strategy that (1) assesses and identifies adverse social impacts of the brand’s climate goals and (2) seeks to cease, prevent, or mitigate these impacts for workers, communities, and other stakeholders
Discloses how the brand consults suppliers in setting climate goals (e.g., net-zero, emissions reduction) that affect the supply chain
Discloses how the brand engages suppliers across the supply chain to co-create locally tailored solutions for climate adaptation, sensitive to regional contexts
Discloses the brand’s efforts to retain, re-skill, and/or up-skill supply chain workers whose jobs are at risk due to the impacts of the climate crisis and/or the brand’s decarbonisation strategy
Discloses efforts to financially compensate workers affected by the impacts of the climate crisis (loss and damage) and/or a brand’s decarbonisation strategy
Discloses real-time heat and humidity levels in production facilities within the brand’s supply chain to assess and track worker heat stress risk (e.g., Wet Bulb Globe Temperatures exceeding 30.5°C for moderate heat stress)
Discloses the number or percentage of supplier facilities covered by collective bargaining agreements
Discloses the number or percentage of supplier facilities that have independent, democratically elected trade unions
The climate crisis is fundamentally an inequality crisis. Communities who contribute the least to global emissions, including millions of garment workers in the Global Majority, are on the frontline of its devastating impacts.
It is profoundly unjust that those with the fewest resources to adapt are also those most exposed to climate hazards – from extreme heat and stifling humidity, to flooding, rising sea levels, and increasingly destructive storms.
It is profoundly unjust that those with the fewest resources to adapt are also those most exposed to climate hazards
In fashion, climate injustice is stark. Emissions are driven by brands’ business models that prioritise relentless production growth and shareholder profit — not by garment workers on poverty wages or the climatevulnerable countries where most garment production takes place. Garments are largely made for export to wealthier markets, yet it is garment workers, whose labour fuels brand profits, who face the mounting risks of unsafe heat at work, polluted air, and unstable livelihoods. In Phnom Penh , factory workers found significantly higher rates of heat-related discomfort and heavy sweating during hotter months, even when Wet Bulb Globe Temperature (WBGT) rose by just three degrees. In Dhaka , peak monsoon rains can increase garment worker sick leave by 10 percentage points, while in Cambodia over 30 percent of garment workers (out of 200 interviewed) report regular exposure to factory-level air pollution.
These risks are both climate impacts and salient human rights risks that should be identified, prevented, mitigated, and accounted for under brands’ human rights and environmental due diligence obligations.
Workers across the supply chain — including farmers, self-employed producers, their representatives, cooperatives, and unions — should co-design solutions that protect their jobs, incomes, health, and communities. This includes ensuring the right to organise, bargain collectively, and engage in genuine dialogue with brands and suppliers.
Brands must share the costs of decarbonisation instead of pushing them onto workers or suppliers, ensure living wages, and invest in protections suited to local contexts so no one – including workers and suppliers – is left behind.
Implementation tools and mechanisms – such as binding agreements, worker-led monitoring, and jointly governed funds – are essential to make these commitments enforceable and sustainable.
A credible Just Transition must directly address this imbalance by putting workers and their representatives at the heart of decision-making, to ensure nobody is excluded by decarbonisation in the fashion industry. This requires genuine, social dialogue so that workers and their independent, democratically elected representatives can co-design climate adaptation and decarbonisation strategies. Without this, brands risk perpetuating the extractive, top-down approaches that created the climate crisis in the first place.
When workers have an independent voice through their representatives and unions, they can lead due diligence processes that identify risks early, push for effective solutions, and hold brands and suppliers to account. Worker-led due diligence, enabled by freedom of association and collective bargaining, is a proven way to ensure solutions are both effective and fair.
Freedom of association and collective bargaining as enabling rights, so workers can organise, negotiate, and influence decisions that affect them — including brand decarbonisation strategies.
Genuine social dialogue between brands, suppliers, and independent unions to ensure that transition plans reflect workers’ needs and local contexts.
Living wages to secure workers the resilience to withstand disruptions and the capacity to invest in their own adaptation — making living wages the single most effective adaptation strategy we have.
Context-specific protections co-designed with workers, such as heat stress prevention measures, flood defences, or social protection schemes.
Fair purchasing practices and financial support from brands to suppliers, so investments in decarbonisation do not deepen supplier debt or push costs onto workers.
For suppliers , a Just Transition means shared or full brand investment in renewable energy and adaptation infrastructure, stable long-term orders to give financial certainty, and collective goal-setting that aligns decarbonisation targets with on-the-ground realities.
ETI’s perception study found a significant knowledge gap across the sector: most factories, brands, and even labour rights organisations are unfamiliar with the concept, and many fail to connect climate action with its potential social impacts on workers.
Our research finds that only 4% of brands publish a Just Transition strategy that identifies the potential negative impacts of their climate goals on workers, communities, and other stakeholders — and sets out how they will stop, prevent, or reduce these impacts. Too often, climate and social issues are treated as separate silos rather than interconnected challenges that must be addressed together.
A Just Transition strategy should:
• Be approved at the highest level of senior leadership, reflecting a formal policy commitment to respect human rights;
• Be publicly accessible and transparently communicated;
• Be developed in meaningful consultation with suppliers, workers, trade unions, and other affected stakeholders;
• Be communicated clearly to suppliers and their representatives, with expectations integrated into contracts and purchasing practices;
• Include mechanisms for monitoring, reporting, and providing or cooperating in remedy where adverse impacts occur;
• Align with recognised frameworks such as the Paris Agreement, the ILO’s Just Transition Guidelines, and the UN Guiding Principles on Business and Human Rights
Only 20% of brands disclose that they consult suppliers when setting climate goals, and just 9% disclose working with suppliers to co-create locally tailored adaptation strategies. Supplier consultation remains largely excluded from brand top-down climate strategies, despite suppliers holding the local expertise needed to design effective, context-specific solutions.
Four out of five brands still fail to consult suppliers in any meaningful way
We are encouraged to see an increase in disclosure on consultation — up from 4% last year to 20% this year — mainly because we awarded points for brands disclosing support that helps suppliers set their own, context-specific targets, including verified ones such as SBTi-approved goals. But four out of five brands still fail to consult suppliers in any meaningful way, particularly on Scope 3 targets where the lion’s share of emissions occur.
Without genuine dialogue, brands risk shifting the costs and responsibilities of decarbonisation onto suppliers instead of sharing them fairly. Co-creating strategies with suppliers — who are experts in their own local context — would make decarbonisation and adaptation plans stronger and supply chains more resilient to climate shocks. Yet very few brands are transparent about taking this approach. This matters because when brands set targets without involving suppliers, they risk walking away from those who struggle to meet new demands instead of working with them to build capacity. The focus should be on fostering social dialogue with existing suppliers to develop climate adaptation and resilience measures locally — not on relocating sourcing to new facilities.
Co-creating strategies with suppliers — who are experts in their own local context — would make decarbonisation and adaptation plans stronger
When asked , a sample of RMG workers in Bangladesh did not see themselves as having any role in addressing climate change 12 — a reflection of deep power imbalances in the sector. This lack of meaningful engagement undermines the effectiveness of HREDD processes, as those closest to the risks are excluded from identifying and addressing them.
Those closest to the risks are excluded from identifying and addressing them
Without the enabling rights of freedom of association and collective bargaining, consultation is unlikely to be genuine or meaningful. Yet progress on brand disclosure has been stagnant. In 2025, only 16% of brands disclose the percentage of supplier facilities with independent, democratically elected trade unions—down from 19% in 2024, despite progress in 2022–23. Disclosure of the proportion of suppliers covered by collective bargaining agreements remains at 14%, unchanged since 2023.
Brand disclosure on consultation is minimal — and consultation alone is not enough. Just 20% of brands disclose how they have consulted suppliers in setting climate targets, and only 9% report engaging workers or communities to co-create solutions. Research by Swedwatch reinforces this gap: worker- and communitydriven due diligence consistently delivers more effective and lasting outcomes in addressing harm — yet such approaches remain severely under-resourced. Resourcing worker-led processes can remediate harms more effectively in fashion supply chains and prevent them from arising in the first place.
12 Findings are drawn from a perception study of 130 respondents in Bangladesh’s RMG sector, providing insight into stakeholder views but not aiming to represent the perspectives of all garment workers in the country.
Research by Cornell University’s Global Labour Institute warns that without proper adaptation, extreme heat and flooding could wipe out almost one million garment jobs and $65 billion worth of exports by 2030 in Bangladesh, Cambodia, Pakistan and Vietnam.
Despite this, just 6% of brands disclose efforts to re-skill or retain workers whose jobs are at risk from the climate transition, and only 3% disclose compensation for climaterelated loss and damage. Without protections like these, the costs of transition will continue to be pushed down the supply chain, onto workers least able to bear them.
Extreme heat and flooding could wipe out almost one million garment jobs in Bangladesh, Cambodia, Pakistan and Vietnam
One of the clearest examples of why meaningful worker consultation matters is heat stress. The way the body experiences heat is shaped by temperature, humidity, and wind speed — combined and measured through the Wet Bulb Globe Temperature (WBGT). Above 30.5°C WBGT, “moderate” heat stress is reached, with well-documented impacts on worker health, safety, and productivity.
In Bangladesh’s garment sector, workers are already facing dangerous conditions. Climate Rights International’s 2025 report “ My Body Is Burning ” confirms that overheated factories — with “feels-like” temperatures reaching nearly 48°C — are causing dehydration, fainting, loss of consciousness, nausea, muscle cramps and even fatalities. Drawing on interviews with over 50 workers, the report describes people collapsing on the job, experiencing severe health impacts, and witnessing colleagues die from heat exposure.
But it is not just Bangladesh. Research from the Solidarity Centre shows that workers in Cambodia at unsafe core body temperatures meet just 61% of productivity targets, compared to 87% at safe temperatures — a nearly 30% drop. Since workers’ earnings are closely tied to how much they can produce, this loss in productivity translates into lower pay. Solidarity Centre finds that incomes are 7.6% lower for those exposed to unsafe heat, and these workers also own 25% less land on average than those not exposed, showing how poverty deepens vulnerability. Union-led interventions — such as negotiating heat protections or warning workers of upcoming dangerous temperatures — reduced unsafe exposure by up to 74%. These productivity and income losses underline that extreme heat is not only a health and safety issue, but also an economic and human rights risk that brands must address under their HREDD obligations.
Despite this, our research shows 0% of brands disclose WBGT or real-time temperature and humidity data from supplier factories. This absence of disclosure makes it harder to integrate heat stress into binding enforcement mechanisms
like the Accord, as reliable baseline data is missing. Without this visibility, brands cannot assess the scale of risk, identify when conditions breach safety thresholds, or track whether adaptation measures are working.
“feels-like” temperatures are reaching nearly 48°C, causing dehydration, fainting, loss of consciousness, nausea, muscle cramps and even fatalities
Heat stress is not just a human rights issue — it is a financially material risk. By 2030, global productivity losses from heat stress are expected to reach 2–2.2% of total working hours annually — equivalent to 80 million full-time jobs or $2.4 trillion in lost productivity. At the firm level, even in advanced economies, just ten additional days per year above 35°C can reduce annual labour productivity by ~0.3%. While these figures are economy-wide, the risks for fashion are acute. Cornell University’s Global Labour Institute Hot Air report finds that in major garment hubs like Karachi and Phnom Penh, WBGT exceedance days (when heat stress passes the moderate threshold of 30.5 °C) have already reached extreme levels — ~115 in Karachi and ~112 in Phnom Penh in recent years. This means workers in these cities are spending nearly one-third of the year in unsafe heat conditions, with serious consequences for both wellbeing and output. This translates into reduced productivity, increased absenteeism, and fragile supply chains — risks that are financially material for investors as well as socially unacceptable for workers.
Investors routinely assess flood, wildfire, and emissions risks — but they are missing one of the most immediate, material climate risks in fashion supply chains: unsafe heat in garment factories. Workers are experiencing rising temperatures that lower productivity, increase health risks, and threaten supply chain stability. Yet brands are not tracking or disclosing even basic data like wet bulb globe temperatures (WBGT). Real-time heat stress data is a practical, low-cost disclosure that helps brands meet climate adaptation expectations — and helps investors evaluate operational risk and alignment with Just Transition principles. This is an impactful low-cost risk mitigation tool. Disclosure now reduces liability and disruption later.
“You can’t do a meaningful climate value and risk analysis unless you have data
on the afternoon temperature, the air surface temperature and the relative humidity your workers are dealing with. One auditor checking the temperature at 8am on a December day in Dhaka — arguably the coolest production hour of the year — won’t cut it”
Jason Judd Executive Director at Global Labor Institute
Union-led intervention could play a crucial role in addressing heat stress and supporting the transition to clean heat. Embedding worker-led WGBT monitoring could help close this critical data gap and reinforce workers as active participants of a meaningful due diligence process. As facilities transition to new technologies, such as heat pumps and electric boilers, upskilling workers will be important to ensure proper operation and maintenance. International union federations can strengthen this approach by acting as a bridge between equipment producers and supplier factories, and by building the capacity needed for a fair transition. A union-led approach ensures these responsibilities are matched with increased pay and recognition, and reinforces workers’ role in ongoing due diligence.
For brands, investing in worker-led monitoring and training is a strong enforcement mechanism for upholding international labour standards and meeting due diligence expectations. Unlike the snapshot compliance of social audits, this approach reflects the UN Guiding Principles on Business and Human Rights, which stress that due diligence must be an ongoing process of identifying, preventing, and addressing risks.
Continuous WBGT Data Capture WBGT, surface temperature, and humidity
Multiple times/day, all seasons
Using cheap, existing tech (e.g. wi -fi enabled digital thermometers)
Public Disclosure
Brand-level transparency on factory WBGT data
Enables comparison and accountability
Integration into HREDD
Data used in worker–union–brand co-design
Informs risk assessments, adaptation plans, and monitoring
Brands must publicly disclose key supplier facility indicators — such as WBGT, surface temperature, and relative humidity — regularly throughout the year and at multiple times per day so that data reflects the full range of conditions their supply chain workers face, not isolated spot checks. Without continuous, time-relevant primary data, suppliers cannot design effective mitigation plans, and affected stakeholders cannot co-design adaptation strategies that reflect real working conditions.
A temperature check is only the first step – the next is turning data into power, protection, and payouts for workers.
Locally led adaptation models show how data, worker agency, and enforceable mechanisms can combine to protect workers from extreme heat.
• In India , the Self Employed Women’s Association (SEWA) piloted parametric insurance for heat waves, paying out when a pre-agreed WBGT threshold was reached. While not in garment factories, it offers a model for protecting workers if embedded in fashion supply chains.
• The Adaptation and Resilience Fund (A&R Fund), hosted by ClimateWorks Foundation, is piloting similar insurance that triggers automatic payouts when dangerous heat thresholds are met — for example, when homes or workplaces reach extreme temperatures. Designed for rapid disbursement and local control over how funds are used, this model could scale to garment-producing countries.
For both schemes, insurers require reliable, location-specific WBGT data to set payout triggers, price premiums, and verify risk. Without robust, ongoing monitoring across supplier facilities, these thresholds cannot be established, payouts cannot be triggered fairly, and risks cannot be verified.
Yet as our research shows, 0% of brands currently disclose WBGT or real-time temperature and humidity data from supplier factories. Closing this transparency gap is a prerequisite for insurance and other heatrelated protections to function effectively in the fashion sector. The feasibility of this ask is clear: wifi-enabled digital thermometers are inexpensive and reliable, and manufacturers, unions and brands can use such data to establish baselines, track productivity changes against WBGT, and calculate the returns on adaptive investments such as cooling systems and flood defences, as highlighted in Cornell Global Labor Institute’s Hot Air report .
Implementation & Enforcement
Embedded in binding agreements (e.g. the Accord) Worker-led monitoring for prevention & enforcement
One practical and scalable solution that has the potential to deliver both adaptation and mitigation is industrial electrification in fashion supply chains. Fashion Revolution is working with climate campaigning organisation Action Speaks Louder on a ‘Clean Heat for Cool Work’ framework which calls for replacing coal, gas and biomass fired boilers and other fossil fuel systems with electric alternatives such as industrial heat pumps which reduce greenhouse gas emissions (mitigation) while also having the potential to improve working conditions on the factory floor by protecting workers from heat stress and reduce harmful air pollution inside factories and in surrounding communities (adaptation). The approach combines lowcost monitoring with high-investment solutions — calling for public disclosure of factory heat data to inform adaptation costs (e.g. cooling systems), give investors a decision-useful metric to assess risks, enable tools like parametric insurance, and establish a baseline to measure improvements from electrification.
‘CLEAN
Track 1
Ongoing WBGT Monitoring Low-Cost, High-Value Transparency
• Continuous WBGT monitoring using affordable, portable tech
• Public disclosure of factory-level data by brands
• Data integrated into worker-led, enforceable adaptation plans
• Enables parametric insurance & early-warning protections
• Enables baseline to measure improvements from electrification
Track 2
Clean Heat for Cool Work Higher-Investment Adaptation & Mitigation
• Clean heat technologies (like heat pumps and electric boilers) powered by renewables to replace fossil fuel powered production
• Lowers emissions and air pollution with the potential to reduce workplace heat
• Paired with renewable energy advocacy to decarbonise power supply
• Joint governance ensures investment decisions meet worker needs
These two tracks — continuous WBGT monitoring and clean heat industrial electrification — illustrate how adaptation and mitigation can be advanced together when brands commit to paying their fair share.
Track 1 is low-cost but high-impact, delivering immediate transparency, prevention, and early-warning systems through worker-led monitoring.
Track 2 requires greater investment, but offers transformative improvements in workplace safety and climate performance when paired with renewable energy advocacy. Both must be embedded in enforceable, jointly governed mechanisms to ensure that costs are not pushed down the supply chain and that worker priorities drive decision-making.
Even in countries where energy grids are not yet fully decarbonised, piloting heat pump installations in clusters of supplier factories can be an important first step. As stated elsewhere in this report, electrification alone can reduce energy use and emissions , even where renewable energy procurement is limited. At the same time, more case studies are needed across diverse geographies to build a stronger evidence base, reduce risks for suppliers, and encourage wider adoption.
When electrification is paired with strong renewable energy advocacy — as explored in the sub-section Renewable Energy Advocacy — the impact is even greater. Investment in grid-scale renewables in production countries, combined with brands leveraging their purchasing power to accelerate clean power expansion, can help suppliers move decisively away from fossil fuels while directly improving workplace safety by removing the need for burning dangerous fuels onsite.
Integrating industrial electrification into a Just Transition framework would mean combining technical retrofits with enforceable labour protections, ongoing workplace monitoring, and genuine worker participation in solution design. For example, to ensure that technology upgrades deliver real benefits, it is vital to connect producers of industrial electrification infrastructure—such as European manufacturers of heat pumps and boilers—with enduser markets in Global Majority production countries. International union federations can play a bridging role here, helping align brands, suppliers, and workers so that new technologies are introduced with the training, capacity building, and support needed to ensure that clean energy investments enable both operational efficiency and decent work.
The takeaway: clean heat does not just decarbonise fashion – it could save lives, prevent injuries, and create safer, healthier workplaces for the people making our clothes.
The best available case study we have seen to date that supports the ‘Clean Heat for Cool Work’ framework, is a heat pump that the Bangjie factory are piloting in Vietnam alongside World Wildlife Fund, Apparel Impact Institute and H&M. The design of the project uses an integrated heat pump that not only provides clean, electrified heat for production but also cools the air inside factories, reducing heat and humidity for workers. This could demonstrate the potential for clean heat to serve as both a mitigation and adaptation solution. More pilots like this are urgently needed to build a robust evidence base showing how electrification can cut emissions while making working conditions safer and cooler.
But isolated pilots are not enough — to scale these solutions and guarantee worker protections, they must be embedded in enforceable mechanisms.
“Shifting
industrial heat to electricity is recognised as an essential part of tackling climate change. Indeed, WWF’s own energy framework calls on industry to ‘electrify all we can’. This timely campaign demonstrates that fashion brands and manufacturers need to work faster to prioritise and deploy electrification solutions in textile supply chains. These solutions are not only good for the climate, but also reduce local air pollution, and heat pumps can also provide clean cooling to protect workers from extreme heat.
Richard Scotney Global Energy Efficiency Lead at World Wildlife Fund
The International Accord is the most proven and enforceable workplace safety mechanism in the global garment sector, with a track record of improving conditions and saving lives. Its model — joint governance between brands and global/national unions, with independent oversight and enforceable obligations — has been uniquely effective in embedding systemic safety improvements since its inception.
At present, however, the Accord’s mandate does not extend to climate-related occupational health and safety risks such as extreme heat, leaving an important enforcement gap.
Fashion Revolution has co-signed an open letter alongside other stakeholders, urging the Accord to expand its scope to integrate protections against heat stress. Embedding measures such as WBGT monitoring, safe temperature thresholds, and adaptation plans within the Accord’s binding, worker-centred framework would help ensure these climate-related risks are addressed as part of brands’ due diligence obligations.
Expanding the Accord’s scope would strengthen a workercentred climate response by extending protections beyond Tier 1 garment factories to Tier 2 processing facilities, where fossil-fuelled boilers pose some of the most dangerous and deadly risks in the sector [1, 2, 3].
Efforts to cut factory heat stress while also reducing the emissions that drive climate change and air pollution are an important step forward. The transition to clean heat has the potential to address both problems at once: creating safer working conditions by lowering heat stress on the factory floor, and cleaning the air outside, where garment workers and their communities are exposed to deadly pollution every day. However, not all workers in fashion’s value chain are based in factories — and their lives are also being shaped by rising temperatures beyond the factory walls.
The transition to clean heat has the potential to both create safer working conditions on the factory floor, and to clean the air outside
That is obviously the case for home-based workers, the vast majority of whom are women. Working from home is already stressful, but if your home becomes unbearably hot, it causes not only health problems but also productivity loss – which in a system that is mostly based on piecerates, aggravates the problem. Decentralised solutions, like solar panels, could be a viable solution to support the energy needed to cool workers’ homes but only if appropriate financing mechanisms are put in place.
But even for factory-based workers, life outside the workplace is marked by heat stress. If children or elderly dependents cannot sleep at night because of high temperatures, workers themselves will not be rested — a burden that disproportionately affects women. Electricity costs will go up if you need to run a fan the whole night. And, structurally, poverty wages mean workers have to live in cramped, badly built housing – often in locations prone to all kinds of climate hazards, from flooding to landslides to storm damage.
That is why living wages should underpin all Just Transition efforts. They provide a much needed buffer to withstand disruptions, enable workers to move to more climateresilient housing and make it possible to access renewable energy. Most importantly, they provide workers with the dignity and agency to adapt their lives on their own terms.
Discloses the brand’s total annual investment in grid-scale renewable energy projects in garmentproducing countries that contribute to increasing the share of renewable energy in the national grid
Discloses evidence of past and current renewable energy political advocacy in supply chains 7%
Disclosed figure for the above annual investment
Discloses outcomes of past and current renewable energy advocacy efforts in supply chains
As has been made clear throughout this report, garment factories and mills continue to rely heavily on fossil fuels to power production. This is not simply a matter of preference — it is the outcome of a structural energy trap. In places like Cambodia, Bangladesh, Pakistan, and Vietnam, grid electricity is still predominantly fossil-fuelled, expensive, and unreliable. Suppliers, already operating on razor-thin margins dictated by brand purchasing practices, choose whatever keeps production running, even if it is the dirtiest energy available, and are locked in based on their installed machinery, like coal boilers.
The chicken-and-egg problem
This creates a chicken-and-egg problem. Suppliers hesitate to replace coal, fossil gas and biomass boilers or diesel generators with electric alternatives when the grid power available is neither reliably clean nor affordable. At the same time, governments and utilities hold back from investing in renewable grids because they see insufficient industrial demand to justify the cost. The result is a selfreinforcing loop that keeps fashion locked into fossil fuels, slows decarbonisation, and undermines the climate targets brands have set but also delays country-level targets. Our 2025 findings show that this is not just an abstract challenge — it is a gap in corporate action.
Expecting suppliers to decarbonise without enabling structural change is self-defeating — it undermines brands’ own climate commitments. Those who profit most from global supply chains — while racking up the biggest environmental costs — must also lead in creating the conditions for a fair and viable transition. They have a responsibility to support enabling environments that expand access to renewable energy and the necessary infrastructure. Crucially, they can use their purchasing power as leverage to signal demand for systemic change.
Key policy areas that influence the transition include:
• The revision of net-metering policies (which allow factories to sell unused renewable power back to the grid),
• Lower import duties on green technologies
• The introduction of new frameworks for power purchase agreements
• A phase-out of coal in priority countries
Despite the importance of corporate engagement in shaping enabling environments for this transition, only a very small proportion of brands (7%) disclose evidence of past or current renewable energy political advocacy in their supply chains, and an even smaller fraction (2%) disclose the outcomes of such work.
Examples of Leadership:
• H&M has worked with policymakers in Bangladesh, Vietnam, China, and Indonesia to shape regulations and frameworks that expand access to clean power — from power purchase agreements to green power trading and rooftop solar reform.
• PUMA has engaged in policy dialogues in Bangladesh, China and Viet Nam on PPAs and fiscal incentives through the UNFCCC Fashion Charter working groups, as well as joining the Asia Clean Energy Coalition to advance direct power purchase agreements in Vietnam and Indonesia.
• Adidas has engaged policymakers to shape regulatory frameworks for sustainability, including successful advocacy for Power Purchase Agreements in Vietnam to expand supplier access to renewable energy.
It is encouraging to see major fashion brands using their influence to support structural changes. However, these examples remain the exception rather than the rule. Without broader participation, these isolated efforts risk being symbolic rather than systemic. To truly accelerate grid decarbonisation in garment-producing countries, more brands must use their leverage consistently and transparently — ensuring that the enabling environment for suppliers to transition away from fossil fuels is strengthened across the sector, not just in pockets.
This year, we introduced a new indicator: “Discloses the brand’s total annual investment in grid-scale renewable energy projects in garment-producing countries that contribute to increasing the share of renewable energy in the national grid.” To be credited, brands must go beyond one-off announcements or media headlines and provide updates on project stages (e.g., planning, construction, operational) alongside measurable progress such as capacity added to the grid. This ensures that reported investments translate into concrete, systemic change, not just publicity.
Our findings show that only 6% of brands report any onthe-ground investment in grid-scale renewable capacity in garment-producing countries. Among the few leaders, investments range from USD $4.3 million (Inditex) to USD $100 million (H&M and Bestseller in a joint pledge). These examples are important signals, and we applaud the leadership of Inditex, H&M and Bestseller to expand renewable energy at a systems level.
Only 6% of brands report any on-theground investment in grid-scale renewable capacity in garment-producing countries
Yet the broader picture is stark: the vast majority of brands are still failing to finance clean energy at the scale required to decarbonise grids in key sourcing hubs. To highlight again, to meet the demands of a clean energy transition, we will have to add as much new capacity to global energy grids as was built in the past 100 years. The urgency is underlined by the fact that while renewable energy capacity has significantly increased, it is not yet at the rate needed to displace fossil fuels entirely; fossil fuels still account for nearly 60 per cent of electricity generation.
The Apparel Impact Institute (AII) has made clear that a credible renewable energy transition requires a threepronged approach:
1. On-site generation (e.g. rooftop solar, heat pumps) to directly cut emissions at facility level.
2. Near-site renewable projects (e.g. shared solar farms or wind clusters connected to industrial parks).
3. Grid-scale transformation to ensure the electricity that powers electrified factories is genuinely clean.
On-site action is important, but without cleaner grids, electrified equipment may still run on fossil fuels. This is why grid advocacy is essential — especially in countries where fashion is one of the largest export industries. Brands collectively represent significant industrial demand, and when they signal that demand to policymakers, it can unlock renewable energy investment.
The path forward is clear. Breaking the chicken-andegg cycle means brands must act on three fronts simultaneously: financing supplier electrification (e.g. replacing coal boilers with electric heat pumps), investing in or securing long-term power purchase agreements with renewable projects in production hubs, and using their influence to support national renewable energy scaleup. Doing this through a Just Transition lens — sharing costs, protecting jobs, and ensuring no community is left behind — will not only accelerate decarbonisation but also strengthen supply chain resilience.
Right now, our data shows that most brands are not yet willing to take these steps. Until they do, the sector will remain stuck in an energy system that fails both the climate and the workers who keep it running. With the rise of climate sceptic politics, supporting the short term financial interests of big lobbies, we are seeing a rollback on environmental legislation globally, with legislation such as the Corporate Sustainability Due Diligence Directive (CSDDD) being heavily watered down to only include direct partners, excluding the lower tiers of the supply chain where the majority of environmental and human rights impacts occur. Similarly, the Commission’s Omnibus proposal weakens key elements of both the CSDDD and the Corporate Sustainability Reporting Directive (CSRD): transition plans are delayed, downgraded from mandatory to optional in the short term, and diluted from aligning with a 1.5°C pathway to simply making “reasonable efforts” towards sustainability. Meanwhile, in the US, the Trump administration has openly proposed dismantling greenhouse gas regulations altogether
These rollbacks threaten to stall the progress that has been made. Instead of creating the enabling environment that would drive systemic change across global supply chains, policymakers are lowering the bar. This undermines the credibility of corporate climate commitments and risks wasting the narrow window left to align the fashion sector with global climate goals.
There has never been a more urgent time for brands to align with international climate goals and support frameworks that expand renewable energy access. International Financial Institutions (IFIs), local experts, energy developers, and manufacturers should use their influence to push for the expansion and enhancement of grid and transmission networks, scaling renewable energy integration and ensuring stable electricity supplies. By aligning with ambitious policy frameworks and resisting diluted standards, brands and financial actors can help secure the conditions needed for deep decarbonisation and safeguard the future of the sector.
Discloses a public commitment to ensure that suppliers transitioning to renewable energy do not procure solar panels or components linked to high risk of state-imposed forced labour (SIFL), and that the brand itself upholds this commitment in its own operations
This research assesses whether major fashion brands ensure that their transition to renewable energy in their supply chains is rights-respecting, including avoiding solar panels and component parts linked to state-imposed forced labour (SIFL). Our focus is on the renewable energy technologies used by suppliers, such as rooftop solar panels.
Indigenous and rural communities face land grabs, toxic pollution, and deadly reprisals
However, the risk of exploitation often begins much earlier in the supply chain, during the extraction of transition minerals like copper, lithium, cobalt, nickel, and rare earths, which are essential to renewable energy infrastructure. While it is beyond the scope of this research to measure these upstream extractive impacts, Fashion Revolution recognises the devastating human cost of transition mineral mining. Global Witness has described the “violent erasure of land and environmental defenders,” as Indigenous and rural communities face land grabs, toxic pollution, and deadly reprisals – despite having contributed the least to the climate crisis.
Forced labour risks also persist further down the supply chain. Around 35 percent of global solar- grade polysilicon came from the Uyghur Region in 2022, down from 45 percent in 2020, and approximately 95 percent of global solar panel supply chains remain exposed to SIFL- linked inputs. This continued and egregious risk is why our research assesses whether major fashion brands take responsibility for ensuring that renewable energy in their supply chains is rights - respecting and free from state - imposed forced labour.
Limiting global warming to 1.5°C requires a rapid move away from fossil fuels. For the fashion industry, this means tackling Scope 3 emissions, particularly those from energy- intensive supplier operations as outlined in the Decarbonisation section. Rooftop solar is one of the most widely adopted solutions for suppliers to reduce emissions and meet brands’ decarbonisation targets.
Research shows almost the entire global solar panel industry is at risk of being implicated in the forced labour of Uyghurs and other Turkic and Muslim-majority peoples, who are subject to systematic persecution, including State - Imposed Forced Labour (SIFL). Without careful due diligence, the solar energy powering garment production risks being tainted by SIFL. Where SIFL state-imposed forced labour cannot be mitigated or remediated, the UN Guiding Principles on Business and Human Rights (UNGPs) make clear that responsible disengagement and divestment are the only appropriate course of action.
Almost the entire global solar panel industry is at risk of being implicated in the forced labour of Uyghurs and other Turkic and Muslim-majority peoples
To ensure a rights - respecting renewable energy transition, fashion brands should publicly commit that neither their own operations nor their suppliers transitioning to renewable energy will use SIFL-tainted solar. These expectations should be embedded in renewable energy strategies and clearly communicated to suppliers. Without this, Scope 3 decarbonisation efforts risk unintentionally replicating the very exploitation the industry seeks to leave behind.
Our research finds that just two brands out of 200 assessed – OVS and Dressmann – currently disclose information on this issue. We look for a public commitment to ensure that suppliers transitioning to renewable energy do not procure SIFL-tainted solar, and that the brand itself upholds the same standard in its own operations. The limited disclosure suggests that while brands are increasingly advancing Scope 3 decarbonisation, many have not yet fully recognised or addressed the human rights risks in solar procurement.
Many brands have made welcome public commitments – for example, in modern slavery statements or under the California Transparency in Supply Chains Act – to avoid sourcing raw materials like cotton from the Uyghur Region. Regulation and enforcement measures, such as the U.S. Uyghur Forced Labor Prevention Act (UFLPA), which presumes that all goods made wholly or in part with inputs from the Uyghur Region are made with forced labour. For fashion, this means that garments containing Uyghur cotton, yarn, or fabric—regardless of where they are cut, sewn, or finished—can be detained or blocked from entering the U.S., creating clear legal, financial, and reputational consequences for inaction.
Just two brands out of 200 assessed currently disclose information on this issue
By contrast, the same level of scrutiny has not yet been applied to solar energy used in garment production, which means that many brands may overlook the SIFL risks in their decarbonisation strategies. Expanding existing SIFL commitments covering cotton and garment sourcing to also include renewable energy inputs is the next critical step to ensure that Scope 3 emissions reductions are achieved without complicity in forced labour.
Fashion industry stakeholders also have an opportunity to use their collective influence. Engaging with expert groups such as The Coalition to End Forced Labour in the Uyghur Region and Anti - Slavery International can support brands in identifying safer solar sourcing. Acting collectively, fashion brands and suppliers can leverage their significant commercial and political influence to encourage divestment from the Uyghur Region and advocate for alternative solar panel and component sourcing geographies.
By closing this knowledge gap and integrating SIFL- related commitments into Scope 3 decarbonisation strategies, fashion brands can ensure their climate actions support a just, rights - respecting transition, strengthening both environmental credibility and human rights due diligence.
Fashion has the technology and leverage to decarbonise, yet progress is stalled by governance failures. Brands keep outsourcing responsibility, prioritising short-term profits over long-term survival. Nowhere is this clearer than in the industry’s failure to tackle heat. Clean heat is the most immediate opportunity to cut emissions at scale — while also lowering indoor factory temperatures, reducing workers’ exposure to heat stress, and clearing toxic air in factories and surrounding communities.
However, seizing this opportunity demands more than pilot projects and pledges. Brands must electrify rapidly, replace coal, oil, and gas boilers with proven technologies like heat pumps and electric boilers — even on fossil-heavy grids — and pair this with time-bound renewable targets, full public disclosure, and prioritisation of truly renewable sources like wind and solar. This transition cannot come at suppliers’ or workers’ expense: brands must guarantee fair and stable purchasing, provide long-term contracts that give suppliers the security to invest in decarbonisation, and ensure workers and their unions can collectively bargain for living wages — the most effective adaptation strategy. Worker-led due diligence must sit at the centre of this transition, embedding continuous WBGT monitoring, upholding freedom of association, and creating protections designed with and for local communities.
At the very moment when transparency and accountability are most needed, some proposals risk weakening due diligence rules and corporate climate obligations. If brands rely on these rollbacks, Tier 2 facilities — the greatest emissions hotspot — may remain in the shadows, slowing electrification and leaving workers exposed. Voluntary measures have clear limits, and fashion’s future competitiveness will depend on anticipating regulatory trends and aligning with international climate and human rights standards, not waiting to be dragged along by them.
But brands cannot do it alone. Investors must push clean heat as a transition indicator, pressure companies to address heat risk, and unlock capital for supplier decarbonisation. Journalists must expose the gap between brand claims and on-the-ground realities. Academics must generate peer-reviewed data on clean heat adoption and worker health impacts in fashion. Civil society must amplify unions and grassroots organisations, monitor whether brand commitments deliver, scrutinise regulatory changes that affect accountability, and push to expand the International Accord to cover unsafe workplace heat. Citizens must scrutinise brand claims, demand worker protections, and stay informed on how policies shape supply chain accountability, renewable energy access, and worker protections — while scrutinising corporate lobbying that seeks to weaken them.
The industry stands at a turning point. If brands continue with accounting tricks and partial measures, they will lose credibility in a world moving beyond fossil fuels. But if they finance supplier electrification, secure renewable power, and commit to genuine partnership with suppliers and workers — supported by pressure from investors, scrutiny from journalists, research from academics, mobilisation from civil society, and informed demands from citizens — fashion can demonstrate how industrial decarbonisation and climate justice can advance together.
The future of fashion will be measured not by what brands promise, but by what they choose to fuel.
What Fuels Fashion? reviews and ranks 200 of the world’s largest and most influential fashion brands and retailers based on the following criteria:
• Annual turnover: Over USD $1 billion*
• Market segments: Includes high street, luxury, sportswear, accessories, footwear, and denim
• Geographic spread: Represents brands from Europe, North America, South America, Asia, and Africa
As major brands in the apparel industry, these retailers have significant negative human rights and environmental impacts and bear an outsised responsibility to drive transformative change. With some of the wealthiest owners and CEOs, these brands have the resources and moral imperative to take meaningful action on transparency and climate impacts, including improving human rights and environmental practices at the core of their business models. More information about targeting large multinational brands can be found in our Q&As .
We list brand names rather than parent company or controlling group names for public familiarity. For brands part of larger groups (e.g., H&M Group, Inditex, PVH), scores reflect all brands within the group unless disclosure varies, in which case scores are disaggregated by brand.
* Note : For privately held brands, turnover estimations are based on publicly available information.
This year, 48% of the reviewed brands and retailers participated by returning a completed questionnaire.
We include all brands in our research, whether they participate or not, and treat them equally. However, participating brands typically score higher as they can highlight relevant disclosures our researchers may have missed or provide additional information.
Fashion Revolution contacts all 200 brands annually at the start of the research cycle.. Brands are informed of methodology updates and invited to participate.
Participation involves brands reviewing their pre-filled questionnaires, filling in any public disclosure we missed, and responding to researcher queries. This process helps brands improve their disclosures and aligns them with industry best practices. As a result, participating brands typically receive higher scores year-on-year.
completed a questionnaire did not respond declined to participate 48% 52% <1%
Abercrombie & Fitch (Ambercrombie & Fitch)
Adidas (Adidas AG)
Aeropostale (Authentic Brands Group LLC)
AJIO (Reliance Retail)
Amazon (Amazon.com, Inc.)
American Eagle
ANTA
Anthropologie (URBN)
Aritzia
Armani (Giorgio Armani S.p.A)
Asda (George.) (TDR Capital)
ASICS
ASOS
Balenciaga (Kering)
Banana Republic (Gap Inc.)
BCBGMAXAZRIA (Marquee Brands)
Beanpole (Samsung C&T)
Belle
Bershka (Inditex)
Big W (Woolworths Group)
Billabong (Boardriders)
Bloomingdale's (Macy's Inc.)
Bonprix (Otto Group)
boohoo (Boohoo group plc)
Bosideng
Bottega Veneta (Kering)
Brooks Sports (Berkshire Hathaway)
Brunello Cucinelli
Buckle
Burberry
Burlington
C&A
Calvin Klein (PVH)
Calzedonia (Calzedonia Group)
Carolina Herrera (Puig)
CAROLL (Vivarte)
Carter's (Carter's Inc)
CELINE (LVMH)
Champion (HanesBrands Inc.)
Chanel
Chico's
Chloé (Richemont)
COACH (Tapestry, Inc.)
Columbia Sportswear
Converse (Nike, Inc.)
Cortefiel (Tendam)
Cotton On (Cotton On Group)
Decathlon (Association Familiale Mulliez)
Deichmann
Dick's Sporting Goods
Diesel (OTB Group)
Dillard's
Dior (LVMH)
Disney (The Walt Disney Company)
DKNY (G-III Apparel Group)
Dolce & Gabbana
Dr. Martens (Permira)
Dressmann (VARNER)
DSW (Designer Brands)
Eddie Bauer (Authentic Brands Group LLC)
El Corte Inglés
Ermenegildo Zegna
Express
Falabella
Famous Footwear (Caleres)
Fanatics (Kynetic)
Fashion Nova
Fendi (LVMH)
Fila
Foot Locker
Forever21
Foschini (TFG)
Fossil (Fossil Group, Inc.)
Free People (URBN)
Fruit of the Loom (Fruit of the Loom)
Gap (Gap Inc.)
Gildan
GU (Fast Retailing)
Gucci (Kering)
GUESS
H&M (H&M Group)
Hanes (HanesBrands Inc.)
Heilan Home
HEMA
Hermès
Hollister Co. (Abercrombie & Fitch)
Hudson's Bay (Hudson's Bay Company)
Hugo Boss
Intimissimi (Calzedonia Group)
Jack & Jones (BESTSELLER)
Jack Wolfskin (Calloway Golf Company)
JD Sports
Jil Sander (Onward Holdings)
Joe Fresh (Loblaw Companies Limited)
John Lewis
Jordan (Nike, Inc.)
Kate Spade (Tapestry, Inc.)
Kiabi
Kmart Australia (Westfarmers)
Kohl's
La Redoute (Galeries Lafayette Group)
Lacoste (Maus Frères)
Lands' End
LC Waikiki
Lee
Levi Strauss & Co
LL Bean
Louis Vuitton (LVMH)
lululemon
Macy's (Macy's Inc.)
Mango
Marc Jacobs (LVMH)
Marks & Spencer
Marni (OTB Group)
Massimo Dutti (Inditex)
Matalan
Max (Landmark Group)
Max Mara
Michael Kors (Capri Holdings)
Miu Miu (Prada Group)
Mizuno
Moncler
Monoprix (Groupe Casino)
MRP
Muji (Ryohin Keikaku Co.)
New Balance
New Look
New Yorker
Next
Nike (Nike, Inc.)
Nine West (Authentic Brands Group LLC)
Nordstrom
Old Navy (Gap Inc.)
Otto (Otto Group)
OVS
Paris (Cencosud)
Prada (Prada Group)
PrettyLittleThing (Boohoo group plc)
Primark (Associated British Foods plc)
Prisma (S Group)
Pull&Bear (Inditex)
Puma
Quiksilver (Boardriders)
Ralph Lauren
Reebok (Authentic Brands Group LLC)
REI
Reliance Trends (Reliance Retail)
REVOLVE
River Island
Ross Dress for Less
Roxy (Boardriders)
Russell Athletic (Fruit of the Loom)
s.Oliver
Sainsbury's (Tu Clothing)
SAINT LAURENT (Kering)
Saks Fifth Avenue (Hudson's Bay Company)
Salvatore Ferragamo
Semir (Semir Group)
SHEIN
Shimamura (Shimamura Co., Ltd.)
Skechers
Smart Bazaar
Splash (Landmark Group)
Sports Direct (Frasers Group)
Steve Madden
Stradivarius (Inditex)
Takko
Target
Target Australia (Westfarmers)
Ted Baker
Tesco (F&F Clothing)
Tezenis (Calzedonia Group)
The Children's Place
The North Face (VF Corporation)
The Warehouse
Timberland (VF Corporation)
TJ Maxx (TJX)
Tod's
Tom Tailor
Tommy Hilfiger (PVH)
TOPVALU COLLECTION (AEON)
Tory Burch
Triumph
Truworths
UGG (Deckers Brands)
Under Armour
Uniqlo (Fast Retailing)
Urban Outfitters (URBN)
Valentino
Van Heusen (Authentic Brands Group LLC)
Vans (VF Corporation)
Vero Moda (BESTSELLER)
Versace (Capri Holdings)
Victoria's Secret (L Brands)
Walmart (Walmart Inc.)
Woolworths South Africa (Woolworths Holdings Limited)
Wrangler (Kontoor)
Youngor
Zalando
Zara (Inditex)
participated in brand questionairre
The methodology for What Fuels Fashion? builds off of the Global Fashion Transparency Index methodology that was first created in 2017. Some of the indicators included were formed in previous years.
The methodology was designed in 2017 through a fourmonth consultative process with a variety of industry experts and stakeholders from academia, the trade union movement, civil society organisations, socially responsible investment, business consulting and journalism. This year we have made significant updates to the methodology in consultation with experts, which included:
Andrew Glumac , CDP
Edward Collins and Faye Holder , Influence Map
Joseph Zacune , Consultant
Killian Daly , Energy Tag
Kim van der Weerd , Transformers Foundation
Kaarina Kolle , Clean Energy Demand Programme Manager, European Climate Foundation Manager
Paul Roeland , Clean Clothes Campaign
Rachel Kitchin , Stand.Earth
Ruth MacGilp , Action Speaks Louder
Silke Mooldijk , New Climate Institute
Peter Ford , Consultant
Illishio Lovejoy , Laudes Foundation
We have strived to align the methodology, so far as possible, with existing international standards and frameworks such as GRI, Open Data Standard, UN Guiding Principles, SDGs, OECD Due Diligence Guidelines, the GHG Protocol and the relevant ILO conventions, as well as other benchmarks and initiatives including ACT, CHRB, Know The Chain, Transparency Pledge and several others. We also collaborate to share research with other benchmarks through our partnership with the open research platform Wikirate
The weighting of the scores is designed to incentivise detailed, granular public disclosure. The intention is to put the greatest emphasis on results, outcomes, impacts and the most actionable data that can be used by external stakeholders to hold brands to account.
• Data is as current as of 15th of May 2025. Brands may have disclosed or retracted information or links to evidence may have moved or stopped working after this date
• Changes to the methodology in may affect year-onyear comparability of the results. Please make annual comparisons with that in mind.
• Desk-based research relies upon people and that means human errors are possible
• Verification of brands’ claims are beyond the scope of this research, only on-the-ground rights holders and experts can hold brands to account when their practices and impacts do not stand up to their claims
We are confident that the methodology is comprehensive and robust when it comes to the public disclosure of actionable information by major brands. Our research team has tried our best to be as thorough, meticulous, objective and consistent as possible across all 200 brands. However, we acknowledge that it can always be improved and welcome your concerns or feedback. You can email us at transparency@fashionrevolution.org .
What Fuels Fashion? covers 78 13 individual indicators across 200 brands comprising 15,600 data points. Visit this link to view the WFF Brand Questionnaire template.
13 We also collect data on 12 additional zero-point indicators. These are not part of the analysis for this research and do not influence brands’ scores. This data is gathered on behalf of our partners at the Clean Clothes Campaign for their Fashion Checker initiative, which compares brands’ public claims on living wages with actual wage slips from workers.
All scores have been calculated to two decimal places (in the complete data set) and then rounded to the nearest whole percentage point for this report.
To calculate the total score for each brand, we add the score awarded to the brand for the five different sections. Each section has a different weight as some sections are worth more points than others:
1 Accountability is worth 21/150
2 Decarbonisation is worth 62/150
3 Energy Procurement is worth 13/150
4 Financing Decarbonisation is worth 19/150
5 Just Transition & Advocacy is worth 35/150
All averages in this report represent the mean.
The overall average score across all 200 brands is calculated by taking the average of all brands’ individual final scores. Year-on-year differences in scores are
described as the change in percentage points rather than the rate of percentage change. This is true unless explicitly stated otherwise. For instance, if a brand scored 30% in one year and 45% in the next, we are usually reporting that the brand increased by 15 percentage points (45-30=15) rather than saying the brand increased by a 50% rate of change (45/30=1.5).
Where a score may have been rounded to the nearest percentage point in previous editions, we are calculating the year-on-year difference according to the rounded figures rather than to the exact decimal points. For example, where the average score in a particular section is 17.74% we have rounded this up to 18%. If in a previous year’s report the average score in that section was 12.41% we rounded it down to 12% in the report. Therefore, the year-on-year difference is technically 5.33 percentage points, but if we go by the nearest rounded figures it is 6 percentage points.
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What Fuels Fashion? was written by Liv Simpliciano, Ciara Barry, Delphine Williot, Ysabl Marie Dobles and Isabella Luglio. Research and writing were carried out between January and August 2025. The report was designed by Molly Porteous. The report was proofed and copy-edited by Maeve Galvin, who we thank for her continued support which we deeply appreciate.
We extend the utmost gratitude to our pro-bono consultation committee, who have been instrumental in guiding our team through this project.
A very heartfelt thanks to the experts who contributed their additional analysis and viewpoints for the report this year. In particular, we thank Ruth MacGilp, Fashion Campaign Manager at Action Speaks Louder, for her technical expertise which has been instrumental to the development of What Fuels Fashion and the Clean Heat for Cool Work framework.
Thanks to all of the representatives from the brands and retailers who participated in the What Fuels Fashion? research. Your participation is both vital and appreciated.
What Fuels Fashion? is funded by the Laudes Foundation , Pooled Fund on International Energy (PIE) and Tara Climate Foundation. We thank them for their ongoing support.
This work is owned by Fashion Revolution CIC (Company number: 8988812).
The research is led by Fashion Revolution’s Head of Policy & Research, Liv Simpliciano.
The Laudes Foundation is an independent foundation and part of the Brenninkmeijer family enterprise, alongside COFRA Group businesses, and the family’s other private philanthropic activities, including Porticus, Good Energies Foundation and Argidius Foundation. The Foundation is independent from the Group and works to influence all of the garment industry, including the COFRA group businesses which includes C&A.
We would like to highlight our fair treatment of fact and our unbiased approach to assessing C&A in the report. We have mitigated any risk of a conflict of interest by the following three methods: viewing and treating C&A and the Laudes Foundation as separate entities; treating C&A like any other of the 200 brands we analysed and not giving C&A any preferential treatment in this or additional assessments of C&A by our technical partner in Brasil, ABC Associados
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For the Raw Data File we make available we are not granting any licence for you to use the Raw Data, which we have compiled to produce this research. You are only permitted to view the Raw Data File.
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© Fashion Revolution CIC 2025
Published September 2025
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What Fuels Fashion? is made available on the express request that it will be used only for general information purposes. Readers are encouraged to form their own views and opinions on each of the brands mentioned in this Report. All content in What Fuels Fashion? is not to be construed as connected to or relating to any form of legal, governance, regulatory, research or investment advice nor any other specific or general advice on buying, selling or dealing in any way with the brands mentioned in this Report. This Report has not been prepared to any specific or general investment objectives. Before acting on anything inspired by anything contained in this Report, you must consider whether it is suitable to your circumstances and, if necessary, seek professional advice. No representation or warranty is given that the material in this report is accurate, complete or up-to-date. The material in this report is based on information that we have found in the public domain and reasonably considered correct at time of publication. Fashion Revolution has not verified, validated or audited the data used to prepare this report.
The assessment of fashion brands has been carried out solely according to the What Fuels Fashion? methodology and no other assessment models used by any of the project partners or our analyst team. Any statements, opinions, conclusions or recommendations contained in this report are honestly and reasonably held or made at the time of publication. Any opinions expressed are our current opinions based on detailed research as of the date of the publication of this report only and may change without notice. Any views expressed in this report only represent the views of Fashion Revolution CIC, unless otherwise expressly noted. The content of this publication can in no way be taken to reflect the views of any of the funders of Fashion Revolution CIC or What Fuels Fashion? .
While the material contained in this report has been prepared in good faith, neither Fashion Revolution CIC nor any of its partners, agents, representatives, advisers, affiliates, directors, officers or employees accept any responsibility for or make any representations or warranties (either express or implied) as to the accuracy, completeness, reliability, or truth, of the information contained in this report or any other information made available in connection with this report, and disclaims all liability for loss of any kind suffered by any party as a result of the use of this What Fuels Fashion? report. Neither Fashion Revolution CIC nor any of its agents, representatives, advisers, affiliates, directors, officers and employees undertake any obligation to provide the users of this report with additional information or to update the information contained therein or to correct any inaccuracies which may become apparent.
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To aid clarity and accessibility, this report displays brand logos in black and white. Logos are included solely to help readers quickly identify the companies being assessed and to illustrate findings in a clear, visual format. All brand logos remain the property of their respective owners and are used here strictly for research, reporting, and public accountability purposes. Their inclusion does not imply any affiliation with or endorsement of this report.
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