SB 707: Who Is Considered a Producer?

California’s SB 707 is redefining responsibility in the apparel and textile industry. America’s first comprehensive Extended Producer Responsibility (EPR) law for textiles, SB 707 shifts how brands, manufacturers, and sellers operate by requiring producers to take responsibility for the full lifecycle of the products they bring to market.

Understanding who qualifies as a “producer” is one of the most important first steps toward compliance—and strategic advantage.

Who Is a Producer Under SB 707?

SB 707 takes a broad view of responsibility. A “producer” is not just the factory making the garment—it includes any entity with meaningful influence over how products are designed, made, imported, or sold in California.

Manufacturers
Companies directly involved in the creation of apparel, textiles, and related products. Manufacturers play a critical role through decisions about design, materials, construction, and production methods.

Brand Owners
Brands that control how products are developed and marketed. This includes making key decisions about materials, quality, pricing, and production partners—even if manufacturing is outsourced.

Importers
Companies that import apparel or textiles for wholesale or distribution in California. Importers are responsible for ensuring the products they bring into the state comply with environmental and recycling requirements.

Retailers
Retailers influence what gets produced through purchasing decisions. By selecting which products reach consumers, retailers play a meaningful role in shaping the market—and may carry producer responsibility under SB 707.

Wholesalers and Distributors
Entities that control product distribution or exert influence over how goods are positioned and sold may also be considered producers, particularly when brand ownership or manufacturing responsibility is unclear.

What Producers Need to Consider Now

As SB 707 takes effect, producers must assess how their businesses operate—from design through end of life. Compliance is not just a reporting exercise—it demands operational clarity, strategic planning, and proactive management of financial exposure and proactive mitigation.

Key areas to evaluate include:

• Material Selection & Product Design
  Durability, recyclability, and material composition will directly affect environmental impact and potential financial obligations.
• Supply Chain Management
  Visibility into sourcing, production partners, and manufacturing processes is essential.
• Lifecycle & End-of-Life Management
  Brands must consider resale, repair, take-back programs, recycling, and responsible disposal—especially for excess and unsold inventory.
• Consumer Communication
  Transparency around materials, care, and end-of-life options will become increasingly important.
• Regulatory Reporting & Compliance
  Accurate tracking, reporting, and participation in approved stewardship programs will be required.

The Bigger Picture

SB 707 is not just about compliance—it’s about accountability. The brands that succeed will be those that embrace lifecycle responsibility as part of their business model, using circularity to reduce risk, build trust, and create long-term value.

Understanding whether you are a producer is the first step. Acting on it is where the opportunity begins and we'd love to help.

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