Sustainability is now part of almost every fashion pitch. It is also one of the easiest places to make a mistake. Words like “eco-friendly,” “green” and “recycled” carry legal and reputational weight, and labels from certification bodies mean specific things. For a young brand, understanding the difference between a claim and a certification is both good ethics and good business.
What New York throws away
Start at home. New York City’s Department of Sanitation (DSNY) measures what residents discard. Its 2023 Waste Characterization Study found that textiles, including clothing, linens and shoes, made up 5.0 percent of residential curbside discards, down from 6.3 percent in 2017. The average household disposed of 92.0 pounds of textiles a year, the lowest weight observed in any of the city’s studies. The largest drop was in clothing, which fell to 35.9 pounds per household in 2023 from 56.8 pounds in 2017.
That is progress, but recovery remains low. DSNY’s Zero Waste Report for fiscal year 2025 counted 178,648 tons of textiles in curbside and containerized collections, against 8,027 tons diverted through DSNY programs and donations reported to the department. That is a textile capture rate of 4.3 percent.
The city’s Textile Recycling Program, run with New York State Industries for the Disabled and Helpsy, offers in-building collection bins and on-call pickup to apartment buildings with ten or more units and to offices, businesses, schools and institutions. According to the report, almost 2,500 buildings were participating by the end of fiscal 2025, the program collected 1,930 tons that year, and more than 20,400 tons have been collected since 2011. Collected items are sorted and reused through secondhand retailers or reprocessed into products such as cleaning rags, seat padding and insulation.
For designers, the lesson is that the end of a garment’s life is part of its design.
The rules on green claims
In the United States, the Federal Trade Commission’s Green Guides, published at 16 CFR Part 260, explain how the FTC applies its ban on deceptive marketing to environmental claims. Three sections matter most to fashion brands.
- General claims. The guides say unqualified general environmental benefit claims, such as calling a product “eco-friendly,” are difficult to interpret and likely to convey a wide range of meanings. Because marketers are highly unlikely to be able to substantiate all of them, the guides say marketers should not make unqualified general claims. Instead, qualify the claim with clear language that limits it to a specific benefit.
- Recycled content. A product can claim recycled content only if it is made of materials recovered or diverted from the waste stream, either during manufacturing (pre-consumer) or after consumer use (post-consumer). An unqualified “recycled” claim is acceptable only if the entire product, excluding minor incidental components, is made of recycled material. Otherwise, qualify it, for example by stating the percentage.
- Recyclable. A product should not be marketed as recyclable unless it can be collected and recovered through an established recycling program. Unqualified claims are acceptable only when recycling facilities are available to a “substantial majority,” defined as at least 60 percent, of the consumers or communities where the item is sold.
Separately, the FTC’s textile labeling rules require that recycled wool be labeled as “recycled wool.” Read more in our fabric guide.
GOTS: for organic fibers
The Global Organic Textile Standard (GOTS) describes itself as a globally recognized certification for textiles made with organic fibers, combining environmental and social requirements with independent certification across the entire processing supply chain. It starts where organic farming ends and covers every step, from fiber processing and spinning to wet processing, manufacturing and trading.
Two points are crucial for brands. First, to label a product as GOTS-certified, every company involved in its production must be certified. Second, GOTS says it requires annual on-site audits of certified facilities and transaction-based verification. In other words, buying certified organic yarn is not enough to put the GOTS label on your finished garment.
OEKO-TEX STANDARD 100: for harmful substances
OEKO-TEX STANDARD 100 answers a different question: has the product been tested for harmful substances? According to OEKO-TEX, every component of a certified article, down to thread and buttons, is tested against a list of more than 1,000 harmful substances. Requirements get stricter the more intensive the skin contact, across four product classes, with Product Class 1, for babies and children up to age three, the strictest.
OEKO-TEX offers an online Label Check where anyone can verify a certificate by scanning the QR code or entering its number. It is not an organic or environmental certification, a distinction many shoppers miss.
A checklist for honest sustainability
- Be specific. “Made with 60% recycled polyester” is clearer and safer than “eco-friendly.”
- Match the label to the claim. GOTS covers organic fiber and processing; OEKO-TEX STANDARD 100 covers harmful substances. Do not use one to imply the other.
- Keep the paperwork. Certificates, supplier documents and test reports are your substantiation.
- Design for the next life. Repairable construction, mono-fiber fabrics and take-back programs can matter more than a hangtag.
Read on: Prato’s history of recycled wool and starting a label in New York.
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Sources
- NYC Department of Sanitation, Zero Waste Report FY2025
- NYC Department of Sanitation, 2023 NYC Waste Characterization Study
- eCFR, 16 CFR Part 260, Guides for the Use of Environmental Marketing Claims
- Federal Trade Commission, Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts
- Global Organic Textile Standard, The Standard
- OEKO-TEX, STANDARD 100
Photo credits: “Clothing bin in Munich” by Kritzolina, via Wikimedia Commons, CC0 (https://creativecommons.org/publicdomain/zero/1.0/deed.en)
Editor’s note: facts in this article were checked against the linked official sources in October 2026. This is general information, not legal advice.
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