Chemical Ban Set to Hit Fashion Supply Chains in 2026
Environmental attorneys Meaghan Colligan Hembree and Amy O'Brien and Senior Policy Advisor Michal Freedhoff co-authored an article featured in Sourcing Journal exploring the impact of the U.S. Environmental Protection Agency's (EPA) updated rule under the Toxic Substances Control Act (TSCA) that will phase out the use of phenol, isopropylated phosphate (3:1) (PIP 3:1) in fashion supply chains starting in 2026. The article describes the new compliance obligations for fashion brands, strategic opportunities for demonstrating leadership in sustainability and transparency, and flexibility offered by built-in exemptions and extended timelines. The authors provide practical guidance for companies to assess their operations, leverage exceptions and proactively adapt to the evolving regulatory landscape while strengthening environmental, social and governance (ESG) messaging.
The authors also published a Holland & Knight alert on this topic.