California Act / Cascadia View / PART III Interview

Wireframe: California Bet to Make Fashion Accountable

Evidence, Assumptions and Uncertainty Shape California’s Textile EPR Debate

California’s attempt to build a large-scale textile recovery system is unfolding with limited precedents and incomplete data. Julie Cerenzia, Director at Cascadia Consulting, explains how the modelling behind the SB 707 debate draws on international comparisons, industry assumptions and evolving market realities to estimate the environmental and economic potential of diverting textile waste.

Subir Ghosh

19 March 2026

6 minutes

Long Story, Cut Short

The modelling behind California’s textile EPR debate draws on international precedents, but translating those insights to local realities remains uncertain.
Climate projections rely heavily on assumptions about reuse rates, substitution effects and end-use pathways within global textile markets.
Cascadia’s analysis highlights how policy design, market demand and infrastructure capacity together determine whether circularity goals become operational realities.

Circular economy policies often rely on analytical models that translate limited datasets into estimates of environmental and economic impact.

Models Wanted Circular economy policies often rely on analytical models that translate limited datasets into estimates of environmental and economic impact. AI-Generated / Freepik

texfash: Your analysis draws parallels with both France’s long-running EPR system and Markham’s landfill ban. In methodological terms, how confident are you that these comparative models meaningfully translate to California’s regulatory and market context?
Julie Cerenzia: One key challenge facing implementation of EPR for textiles in California is that there are very few precedents to learn from. As noted in the report, France’s EPR program operates within commercial, waste management, and cultural environments that differ significantly from California’s. Similarly, in 2024 Markham’s population was less than 1% of California’s, and its waste management system included a ban on landfilling textiles.

While these programmes operate in different contexts from California, they have been operating long enough to publish multiple years of data estimating the degree of diversion they achieved. Data from France and Markham served only as a guide for selecting reasonable assumptions of possible diversion rates, which we could then anchor to when estimating the potential environmental and economic benefits of diversion.

The projected greenhouse gas savings range from roughly half a million to 1.7 million metric tonnes of CO2 equivalent annually, depending on diversion rates and end-use pathways. Which underlying assumptions carry the greatest sensitivity in those projections?
Julie Cerenzia: Our study did not include a sensitivity analysis, so we cannot address which assumptions have the greatest impact on projections. Sensitivity could come from several sources. Cascadia selected 10% and 24% diversion rate scenarios based on the reported performance of the French and Markham systems. For simplicity, we assumed that diverted textiles would contain equal parts cotton and polyester fibres.

Our assumptions regarding the end-use of diverted textiles were based on global data from the Secondary Materials and Recycled Textiles (SMART) trade association, which suggest that 45% would be reused as apparel, 30% would be transformed into wiping rags, 20% would be shredded for shoddy, 5% would go to disposal or incineration, and fibre-to-fibre recycling would account for less than 1%.

We drew assumptions regarding the substitution effect of reused clothing (“replacement rate”) and the per-tonne greenhouse gas savings associated with each fibre type and end-use pathway from the CSA Group’s estimates in its 2024 report “Climate- Smart Circularity: Guiding Decision-Making Through Data-InformeStandard Protocols.” Please see their report for their assumptions and sensitivity analysis.

The substitution effect—that reused garments displace between 60% and 100% of virgin production—underpins much of the climate modelling. How robust is that assumption in a global fashion economy where rebound effects and overproduction remain persistent?
Julie Cerenzia: Those assumptions were also drawn directly from the CSA Group’s analysis. A very limited search of other published research – primarily focused on Europe – also supports replacement rates of 60% to 75%. See, for example, “Environmental benefits from reusing clothes” (2010, DOI 10.1007/s11367-010-0197-y).

TAGS

Company:

Cascadia Consulting Group

Country:

United States

Individual:

Julie Cerenzia

Sector:

Subject:

SB 707

The collector survey reveals a dual sentiment: enthusiasm around funding and end-market development, coupled with apprehension about regulatory complexity and financial exposure. Did you come away with a sense that the sector feels structurally prepared for rapid scale-up?
Julie Cerenzia: Cascadia’s survey did not assess the existing physical or organizational infrastructure for the potential to scale up rapidly. Nonetheless, the survey responses overall appeared to reflect positivity about the potential benefits of EPR, the uncertainty that exists in advance of rulemaking and a PRO Plan, and rational thinking about the financial, operational, and market impact that the new paradigm might have on existing collection systems.

Based on survey responses, current annual collection volumes appear to represent only a fraction of the 1.2 million tonnes being landfilled. Even at a 10% diversion target, volumes would increase dramatically. Is the existing infrastructure within realistic reach of that shift?
Julie Cerenzia: Cascadia’s research did not specifically assess the current available capacity or potential speed of capacity expansion of collection infrastructure.

Our research did find that collectors and others felt that successful implementation of EPR for textiles could dramatically increase diverted textiles, and they expressed concern that a significant, and perhaps rapid, expansion in collection infrastructure would be needed to effectively handle these materials.

While considering the acceleration in global fibre production (see the “Materials Market Report” published by Textile Exchange in September 2025) was outside of the scope of our study for USAgain, Cascadia would note that a continuation of this trend will further increase the capacity needed for collection under EPR.

The municipal case studies—Los Angeles, Oakland, Long Beach, Irvine—illustrate how local ordinances can significantly shape siting feasibility. In your assessment, is regulatory variability the most underappreciated risk factor in California’s EPR rollout?
Julie Cerenzia: There are many risk factors for the successful rollout of textiles EPR in California, most of which fall outside of the scope of this study. These include, but are not limited to, the development of responsible and economically viable end markets; shifts in consumer purchasing and disposal behaviour; and producer responses to changes in the regulatory and market environment.

The overall systems change will be shaped by many complex, inter-related systems dynamics. Municipal regulatory variability was a very salient risk factor for California textile collectors. It is also relatively straightforward to address, particularly if recognized early by municipal policymakers, and the availability of model ordinances helps make this a good area for communities to take early action.

Julie Cerenzia

Director

Cascadia Consulting

The overall systems change will be shaped by many complex, inter-related systems dynamics. Municipal regulatory variability was a very salient risk factor for California textile collectors. It is also relatively straightforward to address, particularly if recognized early by municipal policymakers, and the availability of model ordinances helps make this a good area for communities to take early action.

The San Francisco curbside pilot ultimately proved economically unsustainable, largely due to contamination and value recovery constraints. Does that experience suggest that convenience alone cannot drive viability without strong downstream markets?
Julie Cerenzia: As seen in recycling programs for many different materials, convenient collection alone is not sufficient without viable end markets and a sound funding structure. Lessons learned from this and other pilots offer valuable insights for developing viable material recovery systems. (The California Product Stewardship Council (CPSC) has shared valuable takeaways from past pilots.)

Widening the lens beyond our recent study, economics and systems thinking are what suggest that convenient collections cannot drive viability without strong downstream markets. Convenience for consumers can divert more used textiles, increasing the supply for the circular economy, but there must also be demand and stable markets to absorb that supply, as well as infrastructure to enable the pathways to markets.

EPR is described in the report as a “fundamental paradigm shift.” In practical policy terms, what design features will determine whether SB 707 genuinely shifts producer behaviour—rather than merely reallocating end-of-life costs?
Julie Cerenzia: This question lies beyond the scope of our research for USAgain, but we welcome the opportunity to elevate some critical policy design questions. As with most EPR legislation, the allocation of end-of-life costs will need well-calibrated eco-modulation to shift producer behaviour and design choices toward increased durability, reparability, and recyclability. The needs assessment and PRO Plan will also need to target investment effectively to develop the infrastructure and end markets that can support a circular market for textiles. Policies and programs to change consumer behaviour can also play a role if they shift demand in favour of circular products and lower overall consumption.

The tension between global reuse markets and local economic development surfaces repeatedly in your findings. How should policymakers balance climate efficiency, cost realities and the political imperative for in-state job creation?
Julie Cerenzia: This question is beyond the scope of our research. California’s policymakers will need to navigate many dynamic challenges and policy tradeoffs. Given the commitment demonstrated by local governments, state policymakers, and those operating California’s existing textile reuse and recycling programs, we have great confidence that they will work in earnest to balance the economic, environmental, and social imperatives.

When you look ahead to 2030, what metrics will tell you that SB 707 has succeeded—not simply in diverting tonnage, but in structurally reshaping California’s textile system?
Julie Cerenzia: Based on the stated purpose of SB 707 and our limited literature review, metrics to gauge circularity in the textiles market could track indicators such as the quantity of textiles in the local reuse market, the quantity returned to circulation through repair programs, measures of textile product durability and longer life, or a reduction in the quantity of virgin textiles placed on the market due to replacement or other consumer behaviour changes. The selected metrics will need to align with the SB 707 needs assessment and PRO Plan and, importantly, depend on the reasonable availability of quality data. At this time, much of the data needed to evaluate the textiles market as a circular system is not systematically collected, compiled, or reported.

Key Modelling Assumptions

Diversion scenarios of 10% and 24% were selected using performance data drawn from France’s EPR system and Markham’s landfill ban.
Climate projections estimate savings of 5 to 1.7 million metric tonnes CO₂ equivalent annually, depending on diversion rates and material pathways.
The model assumes diverted textiles contain equal shares of cotton and polyester, simplifying fibre composition across the projected waste stream.
Global reuse and recycling pathways follow SMART industry data, allocating 45% to reuse, 30% to wiping rags, 20% to shoddy.
Fibre-to-fibre recycling represents less than 1% of current end uses, highlighting the limited role of closed-loop recycling today.

System Risks and Capacity

California landfills roughly 2 million tonnes of textiles annually, meaning even modest diversion targets would dramatically increase collection volumes.
Collectors surveyed expressed optimism about EPR funding, but also concern about regulatory complexity and uncertain operational impacts.
Municipal regulations in Los Angeles, Oakland, Long Beach and Irvine demonstrate how local ordinances shape collection site feasibility.
Past pilots, including San Francisco’s curbside textile programme, revealed economic challenges driven by contamination and weak material values.
Expanding textile recovery requires alignment between consumer convenience, stable end markets and viable funding structures.

Subir Ghosh

SUBIR GHOSH is a Kolkata-based independent journalist-writer-researcher who writes about environment, corruption, crony capitalism, conflict, wildlife, and cinema. He is the author of two books, and has co-authored two more with others. He writes, edits, reports and designs. He is also a professionally trained and qualified photographer.

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